PB95-963912
EPA/ROD/R03-95/202
January 1996
EPA Superfund
Record of Decision:
AIW Frank/Mid-County Mustang
Site, West Whiteland Township, PA
9/29/1995
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RECORD OF DECISION
AIW FRANK/MID-COUNTY MUSTANG
SUPERFUND SITE
PREPARED BY
THE U.S. ENVIRONMENTAL
PROTECTION AGENCY
SEPTEMBER 1995
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RECORD OF DECISION
AIW FRANK/MID-COUNTY MUSTANG SUPERFUND SITE
DECLARATION
SITE NAME AND LOCATION
AIW Frank/Mid-County Mustang Superfund Site
West Whiteland Township, Chester County, Pennsylvania
STATEMENT OF BASIS AND PURPOSE
This decision document presents the final selected remedial
action for the AIW Frank/Mid-County Mustang Superfund Site ("the
Site"). The remedial action was selected in accordance with the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 ("CERCLA"), as amended by the Superfund Amendments
and Reauthorization Act of 1986 ("SARA") and the National Oil and
Hazardous Substances Pollution Contingency Plan ("NCP"). This
decision is based on the Administrative Record for the Site.
The Commonwealth of Pennsylvania agrees with the approach of the
Selected Remedy set forth in this Record of Decision.
ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine pursuant
to Section 106 of CERCLA, 42 U.S.C. §9606, that actual or
threatened releases of hazardous substances from this Site, if
not addressed by implementing the response action selected in
this Record of Decision ("ROD"), may present an imminent and
substantial endangerment to the public, health, welfare, or
environment.
DESCRIPTION OF SELECTED REMEDY
The selected remedy described below is the only planned action
for the Site. This remedy addresses excavation and disposal of
contaminated soils and waste, groundwater remediation and an
alternate water supply. Groundwater contamination represents a
primary threat; therefore, the extraction and treatment of
groundwater and an alternative water supply will be required.
Soils and waste onsite represent a low-level threat that may
through future site use adversly affect human health and
groundwater quality; therefore an excavation and off-site
disposal will be required.
The selected remedy includes the following major components:
1. Provision of Point of Use Carbon Filtration Units
(until waterline is extended)
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2. Installation of a water line;
3. Performance of a Phase I archeplogical survey prior to
any intrusive remedial activities.
4. Excavation and off-site disposal of contaminated soils,
following predesign soil investigations;
5. Removal, decontamination and off-site disposal of drums
and sump;
6. Structure Demolition/Restoration
7. Institutional controls (to prevent the consumption of
contaminated groundwater and creation of any
hydraulically adverse influence on the extraction
system operation, including deed restrictions)
8. Performance of an Additional Ecological Assessment;
9. Extraction and treatment via air stripping of
groundwater with vapor phase carbon adsorption and
subsequent discharge to either: 1) West Valley Creek,
2) the on site pond, or 3) the West Whiteland spray
irrigation publically owned treatment works("POTW"),
following a predesign hydrogeologic investigation;
10. Long Term Ground Water Monitoring.
It may become apparent during implementation or operation of the
ground water extraction system and its modifications, that
contaminant levels have ceased to decline and are remaining
constant at levels higher than the Performance Standards
established in this Record of Decision over some portion of the
contaminant plume. If EPA, in consultation with the Commonwealth
of Pennsylvania, determines that implementation of the selected
remedy demonstrates, in corroboration with hydrogeological and
chemical evidence, that it will be technically impracticable to
achieve and maintain the performance standards throughout the
entire contaminant plume, EPA, in consultation with the
Commonwealth may require that any or all of the following
measures be taken, for an indefinite period of time, as further
modification(s) of the existing system:
a) long-term gradient control provided by low level pumping, as
a containment measure;
b) chemical-specific ARARs may be waived for those portions of
the aquifer that EPA, in consultation with the Commonwealth
determine that are technically impracticable to achieve further
contaminant reduction, such determination shall be reevaluated at
each subsequent five-year review;
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c) institutional controls may be provided/maintained to restrict
access to those portions of the aquifer where contaminants remain
above performance standards; and
d) remedial technologies for ground water restoration may be
reevaluated.
The decision to invoke any or all of these measures may be made
during implementation or operation of the remedy or during the 5-
year reviews of the remedial action. If such a decision is made,
EPA shall amend the ROD or issue an Explanation of Significant
Differences.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment and is cost effective,. EPA believes that the
selected remedy will comply with £11 Federal and State
requirements that are legally applicable or relevent and
appropriate to the remedial action. The selected remedy utilizes
a permanent solution to the maximum extent practicable and
satisfies the statutory preference for a remedy that employs
treatment that reduces toxicity, mobility, or volume.
Because this remedy will result in hazardous substances remaining
onsite above health-based levels, a review by EPA will be
conducted within five years after initiation of the remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
Thomas C.
Hazardous Wast
Region III
Date
Division
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AIW Frank/Mid-County Mustang superfund Site
West Whiteland Township, Pennsylvania
Record of Decision
Decision Suaaary
TABLE OF CONTENTS
I. SITE NAME/ LOCATION AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITY 3
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
IV. SCOPE AND ROLE OF THE RESPONSE ACTION WITH SITE STRATEGY . 6
V. SUMMARY OF SITE CHARACTERISTICS AND EXTENT OF
CONTAMINATION 7
A. Site Characteristics 7
1. Surface Features 7
2. Surface Hydrology 7
3. General Site Geology 8
4. Regional Hydrogeology 10
5. Local Hydrogeology . . 10
6. Groundvater Use 11
7. Summary of Aquifer Hydraulic characteristics . 11
8. Demography and Land Use 12
l. Underground storage Tanks ("USTs**) 12
2. Drum Samples 13
3. Asbestos Sampling 14
4. Sump Sampling 14
5. Soil 14
6. Surficial Soil 15
7. Subsurface Soil 16
8. Groundvater 17
9. Monitoring Wells 17
10. Residential Wells 18
11. surface Water 19
12. Sediment . 19
VI. SUMMARY OF SITE RISKS 20
1. Selection of Chemicals of Concern 20
2. Exposure Assessment 21
3. Tozicity Assessment 22
4. Risk Characterization . 23
a. current Use Scenario 23
b. Future Use Scenario 25
B. Environmental Risk Evaluation ........... 26
1. Site Characterization 26
2. Exposure Assessment 27
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3. Risk characterization 27
a. surface water 28
b. Sediments 28
VIZ. DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES 28
~lT Alternative 1: NO ACTION 29
2. Alternative 2: LIMITED ACTIONS 29
3. Alternative 3: LIMITED ACTIONS/PUBLIC WATER
SUPPLY 31
4. Conmon Components of Alternatives 4 & 5 .... 32
a. Soil Investigation 32
b. Ground Water Pre-Design Study 33
5. Alternative 4: GROUND WATER AND SOIL REMEDIATION
34
6. Alternative Si GROUND WATER; SOIL REMEDIATION t
PUBLIC WATER SUPPLY 38
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ... 39
A. Protection of H*1"1*!* Health and the Bnvir
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10. Long Term Groundwater Monitoring 64
X. STATUTORY DETERMINATIONS
of
Vit
riate
Chemical specific ARARs
Location Specific ARARs
Action Specific ARARs
To Be Considered ("TBC") standards
Cost-Effectiveness
Utilization of Permanent Solutions
Treatment Technoloai.es to the
1.
2.
3.
4.
C.
D.
66
66
or Relevant
67
67
68
68
70
71
Alternative
Extent
E.
XI. DOCUMENTATION OF CHANGES FROM PROPOSED PLAN 73
A. Treated Ground Water Discharge options 73
B. Land Recycling and Environmental Remediation Standards
Act (now referred to as Act 2) 75
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RECORD OF DECISION
AIW FRANK/MID-COUNTY MUSTANG SUPERFUND SITE
DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION
The AIW Frank/Mid-County Mustang Superfund Site (the "Site")
is located approximately one mile east of Exton on Route 30 in
West Whiteland Township, Chester County, Pennsylvania. The Site
consists of two adjoining properties, in addition to the areal
extent of contamination which includes the groundwater plume.
The combined area of the two adjoining properties is 16 acres.
The 16 acre site is bounded to the north-northwest by a Conrail
rail line; to the south by Route 30; by open fields to the
northwest, northeast and east-northeast; by Meridian Bank to the
west-southwest; and by the Flotran/Industrial Hose property to
the east-south east (see Figures 1 and 2; Note: all Figures and
Tables are in Appendices A and B respectively).
Geographically, the Site is located within the Piedmont
Physiographic province. Locally, the site is approximately
midway between North and South Valley Hills on the southern edge
of the northeast to southwest trending Chester Valley. Chester
Valley is approximately two miles wide. North and South Valley
Hills are approximately 650 and 600 feet above mean sea level
("msl"), respectively and stand approximately 300 and 200 feet
above the relatively flat lying Chester Valley. The major stream
draining the area is West Valley Creek, a tributary of the
Brandywine, which flows southwest across the northern edge of the
Site. Site elevations range from 330 feet above msl in the
northern portion of the Site to 375 feet msl in the southern
portion. The Site is mapped in the Malvern, Pennsylvania 7.5
minute U.S. Geological Survey (USGS) quadrangle at approximately
40° 01' 50" N latitude and 75° 36' 04" W longitude.
The ground water table in the Site area generally reflects
surface topographic slopes. Site specific data suggests that
groundwater flows from local topographic highs in the former Site
production areas, towards valley bottoms. Drinking water for the
area within 2.2 miles of the Site is supplied by private
residential wells, commercial wells and three water companies.
The Philadelphia Suburban Water Company operates two public water
supply wells directly down gradient from the Site and within
several hundred feet of the leading edge of the contaminant
plume. A number of local residences, and businesses within the
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contaminant plume area have private wells that are currently or
have been used in the past for drinking water supply and other
uses.
The estimated population residing within one mile of the
Site is approximately 916, which includes approximately 175
boarding school students. Approximately 4,680 people reside
between one and two miles of the Site.
The AIW Frank portion of the Site property totals over 15
acres and was used in the past for the manufacture of styrofoam
products and commercial refrigeration units. The former
production areas of the AIW Frank facility are located in the
southern half of the property near Route 30. There were, prior
to 1991, two abandoned buildings, two parking areas, associated
roadways and loading docks on this property. Immediately north
of the parking area adjacent to Route 30 was a 180 foot by 160
foot one story building, referred to as the front building, which
was used by the AIW Frank corporation for manufacturing. On
August 15, 1991, a fire of unknown origin destroyed the front
building. All that remains of the building is the foundation.
The second building, known as the rear building, lies 200 feet to
the north-northeast of the front building. The rear building was
used for both warehousing and manufacturing in the past. The
rear building was gutted after manufacturing was discontinued and
currently contains miscellaneous debris along with a number of
water/gas lines formerly used for fire protection and
manufacturing. The rear building roof partially collapsed during
the winter of 1994/1995. Attached to the rear building was a
small annex containing numerous decomposed concrete blocks. The
annex was dismantled during demolition of the front building.
East of the rear building is the back parking lot area. In
the southern portion of this parking area is the location of a
former above ground waste solvent tank. A driveway and a paved
area containing five to ten above ground tank pedestals lie in
the space between the rear building and front building
foundation. Nearby are several large pipes accessing three
20,000 gallon underground storage tanks outside the boiler room
of the former front building. Liquid can been seen in the tanks
standpipes. The tanks are believed to have been used for fuel
oil storage in the past. A concrete lined drainage ditch crosses
through this area, heading into a concrete culvert near the back
parking lot. The drainage ditch was used to discharge boiler
water to West Valley Creek during the AIW Frank manufacturing
period at the Site.
The northern half of the facility is an open area overgrown
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with weeds, brush and small trees. West Valley Creek flows east
to west, through the northernmost portion of the property, just
south of the Conrail rail line. Downstream, West Valley Creek is
a cold water fishery with protected trout fishing. The creek has
been impounded on the Site property to form a pond measuring
approximately 310 feet by 60 feet (0.4 acres). A 300,000 gallon
water tower, used in the past as a fire protection water supply
for the facility, is also located in the overgrown area north of
the rear building.
The Mid-County Mustang portion of the Site (currently Rex
Carle Automotive Services) is less than one acre in size and
consists of an auto garage, a parking lot, and a small lawn area.
The Mid-County Mustang portion of the Site is bordered by the AIW
Frank property and a private residence to the east; the former
Pipe Maintenance Service (PMS) building to the north; a private
residence to the west; and a small open field, Meridian Bank, and
Route 30 to the south (see Figure 2). The area of concern on the
Mid-County Mustang portion of the Site is a former tile field,
located in the lawn area near the garage. Historical information
indicates that previous operators of the auto garage had steamed
and utilized solvents to clean auto engines. The liquid waste
from the engine cleaning operation was then disposed of in floor
drains in the garage building. From the floor drains the liquid
waste was discharged into the on-site tile field which consisted
of a stone filter bed.
II. SITE HISTORY AMD ENFORCEMENT ACTIVITY
Based on sampling of local private water supply wells in 1982,
the former Pennsylvania Department of Environmental Resources
("PADER"), now known as the Pennsylvania Department of
Environmental Protection ("PADEP"), determined a pattern of
elevated volatile organic contaminants including, trichloroethene
("TCE") in the ground water in the vicinity of the AIW Frank
property.
Analytical results for samples collected from ground water wells
and soils at the Site from 1982 through 1984 by the Department of
Environmental Resources ("PADER1*) and contractors retained by the
owners of both the Mid-County Mustang and AIW Frank portions of
the Site revealed the presence of various volatile organic
compounds ("VOCs"). The contaminants with the highest observed
concentrations were trichloroethene ("TCE"), tetrachloroethene
("PCE") and 1,1,1 trichloroethane ("1,1,1 TCA").
As a result of the investigation conducted by the owner of the
Mid-County Mustang property the contaminated stone filter bed and
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AIWFrank- ROD
associated contaminated soils to a depth of 3 feet were excavated
and disposed of off site under FADER oversight in 1984. Also,
the floor drains in the garage areas were cemented to prevent
future problems of a similar nature.
In the Fall of 1990, Continental Refrigeration Corporation, the
owner of the AIW Frank portion of the Site at that time, removed
and disposed of approximately 30 drums containing mostly
methylene chloride from the rear building under PADER oversight.
An NUS Field Investigation Team under contract to EPA conducted a
multimedia investigation of the Site property and some
surrounding industrial sites in 1985. This study also found
elevated levels of TCE, PCE and 1,1,1 TCA in ground water and
soils. In 1987, EPA performed a hazard ranking system score for
the AIW Frank/Mid-County Mustang Site. The Site was subsequently
proposed for listing on the Superfund /rational Priorities List
('NPL') on June 24, 1988. The NPL is EPA's list of the most
serious uncontrolled or abandoned hazardous waste sites
identified for possible long-term clean up. The Site was
officially listed on the NPL on October 24, 1989.
On May 9, 1990, EPA issued notice letters to those parties who
were considered to be Potentially Responsible Parties ("PRPs11)
for the contamination found at the AIW Frank/Mid-County Mustang
Site. The letters also requested that the parties notify EPA
within 14 days of receipt of the notice letter, whether the
parties were interested in conducting the Remedial Investigation
and Feasibility Study ("RI/FS") for the Site.
Several of the PRPs who received the May 9, 1990 notice letter
showed initial interest in negotiations towards conducting the
RI/FS. However, after limited negotiations EPA determined that
the settlement procedures were not in the public interest at that
time and would not expedite remedial action at the Site. On
September 17, 1990 and September 25, 1990, EPA issued
notification of special notice waiver letters to the PRPs
identified for the Site setting out the Agency's decision to
conclude the negotiations and proceed in conducting the RI/FS.
As mentioned above, on August 15, 1991 a fire destroyed one of
the buildings on the AIW Frank property. As a result, the
remaining portions of the building that were standing were
demolished and the demolition debris was removed and disposed of
at a demolition waste landfill by an EPA contractor.
EPA conducted a Remedial Investigation/Feasibility Study of the
Site to identify in greater detail the types, quantities and
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locations of contaminants and to develop ways of addressing the
contamination problems. Field work for the RI/FS was conducted
between January 1991 and January 1993. The final RI/FS reports
dated April 1995 are in the Site repositories. Additional
residential well sampling was recently conducted by EPA in
February 1995.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Community interest and concern about the Site has been steady
throughout EPA's involvement. EPA issued a Fact Sheet in October
of 1990 which provided information concerning the removal and off
site disposal of approximately 30 drums containing primarily
methylene chloride. The October, 1990 Fact Sheet also provided
information regarding the Superfund clean up process and
activities which would take place at the Site.
On July 8, 1991, a Community Relations Plan was completed for the
Site. The Plan highlighted issues, concerns and interests of the
community located near the Site which were raised during
interviews.
EPA issued a Fact Sheet in July 1992, providing an update of Site
activities including planned field work for the Remedial
Investigation and Feasibility Study ("RI/FS"). The Fact Sheet
also announced a public meeting, which was held on August 5,
1992. The public meeting provided information to interested
parties regarding the RI/FS field work which was about to begin
at the Site.
In October, 1993 EPA issued a Fact Sheet to keep the community
informed of Site related activities. The Fact Sheet briefly
explained the initial findings of the RI, the Superfund Process,
and the nature and extent of Site contamination.
Pursuant to CERCIA S 113(k)(2)(B)(i)-(v), the RI/FS reports and
the Proposed Plan for the AIW Frank/Mid-County Mustang Site were
released to the public for comment on June 16, 1995. These
documents were made available to the public in the Administrative
Record located at the EPA Docket Room in Region Ill's
Philadelphia office, and the West Whiteland Township Building,
Exton, Pennsylvania. The notice of availability of these
documents was published in the Chester County Daily Local News
and the Philadelphia Inquirer Chester County Neighbors Section on
June 16, 1995.
A public comment period on the documents was held from June 16,
1995 to July 17, 1995. A timely request for a 30-day extension
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AIW Frank -ROD
to the public comment period was made on June 28, 1995. As a
result, the closing date for the public comment period was
extended to August 15, 1995. In addition, a public meeting was
held on June 29, 1995. At this meeting, representatives from EPA
answered questions about conditions at the Site and the remedial
alternatives under consideration. Also, on July 20, 1995,
representatives of EPA met with a local civic association to
answer questions about the remedial alternatives under
cons iderat ion.
The responses to all comments received during the public comment
periods are included in the Responsiveness Summary (Appendix E),
which is part of this Record of Decision ("ROD").
This decision document presents the selected remedial action for
the AIW Frank/Mid-County Mustang Site, West Whiteland Township,
Chester County, Pennsylvania, chosen in accordance with CERCLA,
SARA, and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R.
Part 300. The selection of the remedial action for this Site is
based on the Administrative Record.
IV. SCOPE AND ROLE OF THE RESPONSE ACTION WITH SITE STRATEGY
The Selected Remedy described in this Record of Decision will
comprehensively address the threats posed by the release of
hazardous substances at the Site. The principal threats posed by
the Site are due to VOC contamination in the ground water and on-
site surface and subsurface soils.
EPA has classified the affected aquifer at the site as a class
IIA aquifer, a current source of drinking water, in accordance
with the EPA Document "Guidelines for Groundwater Classification:
(Final Draft, December 1986) . The concentrations of contaminants
in the ground water at the Site are above Maximum Contaminant
Levels ("MCLs") which are enforceable, health-based drinking
water standards established under the Safe Drinking Water Act
("SDWA"), 42 D.S.C. §§ 300f to 300J-26.
The primary objectives of EPA's action at the Site are: to
prevent current or future human exposure to contaminants in the
ground water, soils and sub-surface soils; to minimize migration
of contaminated ground water; to restore ground water to MCLs; to
protect uncontaminated ground water and surface water for current
and future use, and to protect environmental receptors.
This ROD will: 1) address the ground water contamination; 2)
provide a potable source of drinking water for affected and
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AIWFrank- ROD
potentially affected residents; 3) address surface and subsurface
soil contamination; and address the drums, sump and unsafe
condition of structures on the AIW Frank property.
V. SUMMARY OF SITE CHARACTERISTICS AND EXTENT OF CONTAMINATION
A. Site Characteristics
1. Surface Features
The AIW Frank/Mid-County Mustang Site is located within ;the
Piedmont Physiographic Province. The Piedmont Province is an
extensive, southeastward-sloping region characterized by intense
folding and faulting with a gently undulating topography.
Landforms within the province are closely related to the
lithology and structure of folded bedrock, characterized by long
narrow valleys paralleling mountains and steep hills.
Locally, the site is approximately midway between the North
and South Valley Hills on the southern edge of the northeast-
southwest-trending Chester Valley. Chester Valley is
approximately two miles wide and has an approximate elevation of
350 feet above msl. The major stream draining the area is West
Valley Creek, which flows southwest across the northern edge of
the AIW Frank property. Site elevations range from 330 feet
above msl in the northern half of the site to 375 feet above msl
in the southern half of the site.
2. Surface Hydrology
Several surface water streams and drainageways within the
vicinity of the site are all related to and eventually discharge
into West Valley Creek. Surface water runoff from the northern
half of the site generally flows northward approximately
1,000 feet, eventually entering West Valley-Creek and the portion
of the creek that is impounded on the AIW Frank property. This
surface water impoundment is approximately 0.4 acre in size. The
surface impoundment area was determined to be a jurisdictional
wetlands area during the RI. Figure 16 delineates the on site
jurisdictional wetland area, as well as, off site wetland areas
constructed by the Pennsylvania Department of Transportation as
part of a wetlands mitigation project. A man-made drainage ditch
located approximately 100 feet north and east of the two AIW
Frank buildings, and several natural drainageways farther east of
the buildings also drain surface water toward the north into the
impoundment of West Valley Creek.
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West Valley Creek has several tributaries in the area;
however, only two tributaries outline the area of interest. One
unnamed tributary to West Valley Creek, originating from two
springs southwest of the site, flows northwest, passing through a
culvert under Route 30 and eventually merging with West Valley
Creek north of the Conrail (Reading Railroad) property and east
of Ship Road. The unnamed tributary maintained a constant flow
of surface water during field activities, and West Valley Creek
and another unnamed tributary experienced dry periods. Another
unnamed tributary located approximately 1,200 feet east of the
AIW Frank warehouse defines the property line with the Church
Farm School. This tributary originates south of Route 30 in the
West Whiteland Business Center and flows to the north, entering
West Valley Creek northeast of the site area. This tributary is
usually dry except during periods of excessive rainfall. West
Valley Creek flows west-southwestward for approximately
7.2 stream miles before discharging into the East Branch of
Brandywine Creek [Figure 3].
The flow rate of West Valley Creek just west of North Ship
Road during low flow conditions as measured at staff gauge G4
during the RI was .465 cubic feet per second. The width of the
creek at this location is 6.4 feet and the measured depth of
water was one and three quarters of an inch (1 3/4") .
Flow rates of West Valley Creek, approximately 6.5 miles
southwest (downstream) of the site (at Mullstein's Meadows near
Downingtown), ranged from 0.05 to 12 cubic feet per second (cfs)
between 1983 and 1988 (USGS, 1983-1989).
Stream flow rates and cross-sectional measurements were
collected from each surface water/sediment sampling location
[Figure 4].
Surface drainage in the region can be affected to some
degree by karst features of the underlying carbonate bedrock.
Although there are no obvious surficial karst features on-site,
some karst-type depressions are evident southwest and north west
of the site area.
3. General Site Geology
The geology of the study area consists of unconsolidated,
silty, clay-rich soils overlying the bluish-gray limestone and
dolomite of the Conestoga Limestone, Ledger Dolomite, and the
Elbrook Formation. Based on borehole logs from the RI,
overburden thickness ranges from six feet to 75 feet throughout
the site. Locally, the overburden is known to be up to 90 feet
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thick. The soils are derived from weathering of the Conestoga
Limestone and Ledger Dolomite (NUS, 1986).
Fracturing within the Conestoga Limestone is moderately
abundant and poorly formed, with joints having an irregular
pattern. Many of the fractures are open, but some are filled
with secondary quartz and calcite. The formation has a moderate
to low permeability with joints and some solution channel
openings providing a secondary porosity of low magnitude (NUS,
1986). Five voids were encountered in monitoring wells MW-ioi,
MW-103B, and MW-107B,. all of which are drilled into the Conestoga
Limestone. Two voids in MW-101 were encountered at depths of 80
to 84 feet below land surface and 97 to 100 feet below land
surface. One void in MW-103B was encountered at a depth between
45 feet and 49 below land surface. The last two voids in MW-107B
were encountered at depths of 43 to 47 feet below land surface
and 54 to 56 feet below land surface.
Although surface irregularities typical of karst topography
have not been observed at the site, several features that might
indicate karst have been noted in the surrounding area.
Specifically, there are what appear to be a few scattered
sinkholes located to the southwest of the study area in the
carbonate units along the margin of the Chester Valley.
Regionally, karst topography has developed in the Conestoga
Limestone and Ledger Dolomite in other areas. There is one swale
depression into which groundwater in the northern portion of the
site has been observed to be discharging. That feature may be
karst related. Apparent fracture traces identified on aerial
photographs may be associated with or have some control over
karst features in the bedrock. Subsurface solution channels and
voids were evident in most of the monitoring wells installed for
the RI. Those karst features are undoubtedly a significant
influence on hydraulic properties of the rock and the flow of
groundwater and dissolved contaminants.
A total of 22 fracture traces were identified in the general
study area during the course of the aerial photography analysis
(EPIC, 1992). A figure was prepared using reproductions of aerial
photographs for the study area with the confirmed fracture
traces. These photographs were viewed with a stereoscope, and
the linear features (i.e., the suspected fracture traces) were
marked on an overlay. The linear features were field checked to
eliminate man-made or other non-geologic features such as
drainage ditches, unpaved roads, fences, and wildlife pathways.
A final map, based on the field check, was also prepared. These
fracture traces are shown on Figure 5.
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4. Regional Hydrogeology
The regional limestone/dolomite formations (Conestoga and
Ledger) constitute the major source of groundwater in the Chester
Valley. Studies by the USGS indicate that those two formations
plus the Elbrook (where present) act as a single hydrologic unit
based on the observation that static water levels do not
significantly change along lithologic contacts or faults and that
the overall groundwater flow direction follows topography
(Wood, 1984). As a result, the general groundwater migration
pattern is expected to be from the valley, margins to the central
portion of the valley, then down valley to the southwest. Local
flow directions will be controlled by fracture orientations and
can be expected to vary from the overall pattern somewhat.
5. Local Hydrogeology
The local aquifer is formed by the carbonate bedrock units
that underlie the area. These include the Conestoga Limestone
and Ledger Dolomite at the site. Groundwater migration through
these units is through fractures and solution channels and along
bedding planes within the rock mass. Intergranular permeability
and porosity are very low.
The water table at the site is found within the bedrock
material. Depth to groundwater ranges from nine to 26 feet below
ground surface throughout the study area.
A northwest- to-southeast-trending groundwater divide that
bisects the AIW Frank portion of the site has been delineated.
On the north side of this divide, groundwater flows from the
center of the former production area at AIW Frank to the north
and northwest for approximately 1,000 feet, then discharges into
West Valley Creek. On the south side of the groundwater divide,
groundwater flows to the west and southwest for approximately
900 feet and discharges into an unnamed tributary of West Valley
Creek. The potentiometric surface map for the intermediate unit
shows the reported orientation of the on-site groundwater divide
[Figure 6].
The Conestoga Limestone displayed a greater abundance of
solution cavities/voids than did the Ledger Dolomite in the site
vicinity. However, the Ledger Dolomite appeared to have a
greater abundance of fracture zones than the Conestoga Limestone.
There did not appear to be any consistent change in hydraulic
properties associated with contacts between various geologic
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AIWFrank- ROD
stratigraphic units logged for the RI monitoring wells.
The water-table in the site area generally reflects surface
topographic slopes. Site-specific data suggest that groundwater
flows from the local topographic highs, including the former
production area at the site, toward valley bottoms. These water
levels correspond to higher elevations than the nearby portions
of West Valley Creek and its tributaries. The valley bottom
streams often serve as discharge zones for groundwater. However,
in some reaches of the streams (West Valley Creek, for example),
the water-table is lower than the stream level. This local
condition is probably caused by high-permeability solution
channels in the bedrock parallel to the stream. Therefore, in
general, shallow groundwater appears to be hydraulically
connected to surface water in the local area and that the overall
groundwater flow direction from the site is to the northwest and
southwest, toward the local streams and then down the valley.
6. Groundwater Use
Drinking water in the vicinity of the site is supplied by
individual residential wells, commercial wells, and three water
companies.
In the Exton area, Philadelphia Suburban now operates the
system formerly operated by the West Whiteland Municipal
Authority. Water is obtained from two wells on Swedesford Road,
1/4 mile east of Route 100, that draw from the Ledger Dolomite.
The local areas relying on private wells for their drinking water
include the eastern, north-central, and west-central portions of
West Whiteland Township (including the site area) and West
Pikeland Township.
A number of local residences and businesses have private
wells that are currently or have in the past been used for
drinking water supply and/or other uses.
7. summary of Aquifer Hydraulic Characteristics
As explained above, ground water flow and contaminant
transport at the site and vicinity are controlled principally by
secondary permeability features, such as fractures and solution
channels in the carbonate rocks of the Conestoga Limestone and
the Ledger Dolomite. On a large scale, in general, those
formations have sufficient hydraulic conductivity to yield
significant quantities of water to wells (commonly 10 to 100
gpm). However, on a smaller scale, due to the secondary and
heterogeneous nature of the permeability features, there is a
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AIWFrank -ROD
wide variance in hydraulic conductivity (or transmissivity) among
individual wells. The significant large-scale hydraulic
conductivity of the aquifer is confirmed by the lateral and
longitudinal migration of groundwater contamination from the
site.
8. Demography and Land use
The study area exhibits a diverse array of land uses.
Historically agricultural in nature, much of the area is still
farmed. These areas are primarily located off Swedesford Road.
The area along Route 30 is now primarily commercial and light
industrial, with some residential units still present. The area
immediately west of the study area becomes more residential in
nature as Exton is approached.
Based primarily upon house count utilizing USGS topographic
maps, the population residing within one mile of the approximate
center of the study area is estimated to be approximately 916,
which includes approximately 175 resident students at the Church
Farm School. Approximately 4,680 people reside between one and
two miles of the study area, and an additional 6,570 people
reside between two and three miles. Thus, the total population
within three miles of the center of the study area is more than
12,000.
B. Nature and Extent of
This section presents a summary of the nature and extent of
contamination in the soil, groundwater, surface water, and
sediment as well as potential sources such as USTs, drums, on-
site building materials, and a sump. An asbestos survey and
associated testing was also conducted on building materials
collected from the front and rear buildings.
l. Underground storage Tanks ("USTs")
Table 1 presents the results for the laboratory analyses of
the samples collected from the five sampled USTs [Figure 7].
Samples TK-01, TK-02, and TK-O3 are all from tanks located in
close proximity to one another and will therefore be discussed
together. In general, relatively few compounds were detected in
the three tank samples and the analyte concentrations were also
relatively low. Tank TK-01 had the fewest compounds, which
included methylene chloride (4,964 mg/L) , fluorene (9 mg/L) ,
phenanthrene (8 mg/L) , di-n-butyl phthalate (1 mg/L) , and pyrene
(2 mg/L).
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AIW Frank-ROD
Samples TK-02 and TK-03 had a greater number of compounds
than sample TK-01. Most notable were the benzene, toluene,
ethylbenzene, and total xylene (BTEX) components. BTEX compounds
are common components of petroleum products, such as fuel oil.
The remaining compounds were very similar to those found in TK-01
with the exception of naphthalene-type compounds, which are also
components of petroleum and coal-tar products. Tanks TK-01, TK-
02, and TK-03 are believed to have been used for storing No. 6
fuel oil for heating.
Samples TK-04 (liquid) and TK-05 (solid) located next to the
Rex Carle garage, also contained relatively few compounds,
although concentrations, particularly in TK-04, were noticeably
higher. Tanks TK-04 and TK-05 are also believed to have
contained a petroleum-based heating oil. It should be noted that
because these tanks contain petroleum product they are
specifically excluded from Superfund authority and will not be
addressed in the Superfund actions at the Site. The USTs will be
referred to the appropriate State and Federal programs and will
be appropriately addressed under those programs.
2. Drum Samples
As part of the building site visit conducted during the RI,
four samples were obtained from drums containing a solid foam
type substance that were located in the northeast corner of the
rear building [Figure 7].
All of the compounds detected at low levels in the drums are
consistent with the previous manufacturing activities at the
site: Acetone is used largely as a solvent; 1,1,1-TCA is used
primarily as a solvent for degreasing and metal cleaning; 4-
methyl-2-pentanone is a solvent and denaturant with a wide
variety of applications; styrene is a component of paints,
adhesives, metal cleaners, and polystyrene; chlorobenzene is used
as an industrial solvent and a solvent for pesticides; benzoic
acid is used as a preservative and antimicrobial agent;
butylbenzyl phthalate and bis(2-ethylhexyl) phthalate are
components in plastics; di-n-octyl phthalate is a plasticizer for
polyvinyl chloride; and Aroclor 1254 contains PCBs, which was
formerly used in a variety of ways including electrical
capacitors, electrical transformers, plasticizers, cutting oils,
and pesticide extenders [Table 1].
3. Asbestos Sampling
20 samples were collected from various building materials
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AIWFrank -ROD
suspected of containing asbestos. The locations of each asbestos
samples are shown in Figure 8. The results of the asbestos
analysis are summarized in Table 2.
Of the 20 asbestos samples analyzed, six indicated the
presence of asbestos fibers from the front building at the AIW
Frank property. All the asbestos containing building materials
were removed from the Site during the front building demolition
following the August 1991 fire. Sampling analysis results of
samples collected from the rear building and water tower pump
house did not indicate the presence of asbestos.
4. Sump sampling
Two samples were collected from a sump located approximately
50 feet from the east property line and 50 feet from the
southeast corner of the foundation [Figure 7]. One sample, SMD-
01, was collected from the sediment in the bottom of the sump,
and a second sample, SMP-Ol, was collected from the liquid
contained by the sump [Table 1]. All of the compounds detected
in the sump had previously been detected in either tank or drum
samples.
Relatively few compounds were detected in the sump samples.
The most significant finding is 670 mg/kg of Aroclor 1254 in
sample SMD-01 .
5. Soil
During the RI, several activities were undertaken in an
attempt to gain a better understanding of the extent and
magnitude of soil contamination on site as well as to identify
possible additional sources that could potentially contaminate
other media. These activities involved both geophysical and
soil-gas surveys which were designed to guide surficial and
subsurface sampling activities.
The surveys resulted in a number of areas being targeted for
further investigations including the former solvent tank area,
the UST area on the AIW Frank property, and the former tile field
on the Mid-County Mustang property.
6. surficial Soil
Fourteen surficial soil samples (taken from the upper three
inches of soil) were collected in order to assist in defining
potential sources of contamination as well as the nature and
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ATW Frank- ROD
extent of surficial contamination [Figure 9]. Two samples were
collected from off-site background locations in the vicinity of
MW-101 (SO-15 and SO-16) . Five samples were collected from the
drainage ditch that, in the past, directed discharge waters from
plant boilers northward to West Valley Creek (SO-4, -5, -6, -7,
and -8) . Organic compounds were detected at relatively low
concentrations in the surficial soils. In general, the most
common types of contaminants found were semivolatile organics and
pesticides in the Atg/fcg (PPb) range.
Of particular interest is that almost all of the
semivolatiles and pesticides found in the on-site samples were
also detected in background sample SO-15 at comparable levels
[Tables 3 & 4]. Low levels of pesticides are relatively well
distributed among the samples, which suggests that they were
dispersed relatively uniformly and may be related to long-time
agricultural use near the site. Furthermore, Aroclor 1254, which
was found in 10 of the 14 surficial soil samples, may be a
remnant of pesticide applications where Aroclor was used in
conjunction with pesticides to increase their effectiveness,
however, it should be noted that Aroclor 1254 was not detected in
surface soil background samples. Phthalates, which are also
detected in nearly all the samples, are commonly used in industry
as plasticizers. The widely dispersed nature of this contaminant
suggests that it was also uniformly deposited, probably by the
wind. The relatively wide distribution of pesticides and
phthalates indicates that they should be classified as an areal
rather than a point source regarding potential impacts on other
media (e.g., groundwater, wetlands).
The samples from the former solvent tank area indicated only
minimal levels of organic contaminants and two of the samples
contained no VOCs. Sample SO-7 from the ditch contained some of
the greatest organic compound levels found among all the
surficial soil samples. However, those concentrations were still
at low Atg/kg levels.
Two other samples, SO-11 and SO-12 located immediately
northeast of the rear building, also contained higher
concentrations of organic compounds, primarily PAHs, than the
other samples, yet still at low /ig/kg levels.
The concentration of inorganic analytes for most samples
were within the ranges found in the background samples.
For the metals that exceeded background levels, most show
the exceedance in only one or two samples.
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AIW Frank - ROD
Five samples (SO-4, SO-5, SO-6, SO-7, and SO-8) were
collected from the drainage ditch that, in the past, directed
discharge waters from plant boilers.
One surficial soil sample, SO-04, had a mercury
concentration of 1.1 mg/kg, which is slightly above the highest
background level detected (0.8 mg/kg).
The inorganic analyses for surficial soils indicated
somewhat elevated concentration of metals (copper, lead, nickel,
and zinc) in the upper reaches,of the former boiler water
drainage ditch. Samples SO-12 from near the northeast corner of
the rear building (near the ditch) also had elevated levels of
some metals. No other patterns of inorganic contamination were
at levels of potential environmental significance in surficial
soils at the site.
7. Subsurface Soil
A total of nine subsurface samples (deeper than six inches
below land surface) were collected for laboratory analysis. All
of these samples were obtained from the general area of the
former waste solvent tank [Figure 10].
Results of the organic analyses of subsurface soil samples
are summarized in Table 5. Of the subsurface soil organic
analytical results only TCE, 1,1,2-TCA, PCE, l,l-DCE, 1,1-DCA and
1,1,1-TCA were present above site background levels.
Results of the inorganic analyses of subsurface soil samples
from the RI are presented in Table 6. The concentrations of
inorganic analytes for most of the samples were within the ranges
found in the background samples. However, the results indicate
that the following metals were found in one or more samples at
concentrations above the ranges of background samples: aluminum,
arsenic,, beryllium, chromium, cobalt, lead, nickel, silver,
vanadium, and zinc. Aluminum, arsenic, beryllium, chromium,
lead, and silver exceed site background in only one sample at
relatively low concentrations. Therefore, it does not appear
that site activities contributed to any significant contamination
in regards to these metals.
The only inorganic hazardous substances that have
concentrations that significantly exceed site background
concentrations in more than one sample are cobalt, nickel,
vanadium, and zinc. The elevated concentrations of these metals
could be a result of previous on-site activities.
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AIW Frank - ROD
Cobalt: concentrations tended to be higher in all subsurface
soil sample especially in SS-03 at 81.2 mg/kg which is
significantly higher than site background concentrations ranging
from 9.0 to 10.3 mg/kg.
Subsurface soil samples TP-01-B (119 mg/kg) and SS-03-01
(252 mg/kg) had the highest concentrations of nickel, although
the majority of the samples had concentrations of nickel
relatively close to the surficial soil background values.
Concentrations of vanadium in the subsurface soils were
considerably greater than those measured in the site background
samples. Two of the subsurface soil samples had vanadium
concentrations significantly above background and two test pit
samples had concentrations ranging from 234 mg/kg and 286 mg/kg
(TP-01-02 and TP-01-01M).
In all subsurface soil samples, zinc ranged between 32.0
mg/kg and 58 mg/kg, with the exception of sample SS-03-01, which
had a concentration of 380 mg/kg.
8.. Groundvater
This section presents information on the nature and extent
of groundwater contamination in the vicinity of the site. Data
from the chemical analysis of groundwater samples collected from
monitoring wells, and from off-site residential wells are
presented.
9. Monitoring Wells
During the RI, 13 monitoring wells were installed on and off
site to supplement information previously gathered from existing
monitoring and residential wells [Figures 11 & 12]. The
objective of the investigation was to provide an expanded
assessment of the horizontal and vertical extent of groundwater
contamination near the site. Each of the 13 monitoring wells was
sampled twice. Monitoring wells were installed to various depths
to allow both the vertical and areal extent of groundwater
contamination to be assessed. The maximum concentrations of
organic compounds are summarized in Table 7.
The maximum concentrations of inorganics (filtered and
unfiltered) detected in the groundwater samples are summarized in
Table 8.
Based upon the scattered distribution of metal
concentrations in groundwater, and the poor correlation between
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AIW Frank - ROD
inorganic and organic contaminants, there is no apparent wide-
spread metals contamination attributable to former site
activities or sources.
Figures 13, 14, and 15 provide isoconcentration contours of
the TCE distribution in each of the three water bearing zones
(depths). Also Table 9 summarizes the most frequently detected
organic concentrations for each of the three depth
classifications of the wells. In general, contaminant
concentrations tend to decrease with distance west from the site
boundary along Exner Lane. Also, contaminant concentrations tend
to increase with depth, particularly among wells located in close
proximity to the former solvent tank.
Site related ground water contaminants also have the
potential to act as dense nonagueous phase liquids ("DNAPLs").
DNAPLs are contaminants which do not readily dissolve in water,
and are denser than water. DNAPL contaminants are heavier than
water and sink in the aquifer. The ONAPL acts as a continuing
source for dissolved contamination in the aquifer. DNAPLs are
not believed to be present in the aquifer. EPA believes that
sufficient information regarding ground water movement and
contamination was collected during the RI to move ahead with this
Record of Decision for the Site. The actual presence of DNAPL
will be determined during the design phase of the remedy
implementation.
10. Residential Wells
During the RI a total of JL3 residential, municipal and
commercial drinking water wells were sampled in the vicinity of
the site in January, 1993 [See Figures 11 & 12]. The samples
were analyzed for volatile organics, and three constituents were
found in significant concentrations; 1,1 DCE, TCE and 1,1,1 TCA.
The drinking water well results correlate with the
monitoring well concentrations in that the highest concentrations
are in the vicinity of the site and concentration steadily
decrease downgradient of the Site to the west. The wells with
the highest concentrations of contaminants are HW-06, HW-io and
HW-13. The results for the wells sampled in January 1993 are in
Table 10.
In February, 1995 another round of residential and
commercial drinking water well sampling was conducted. The
results of the January 1993 sampling were confirmed by the
February 1995 sampling. The results of the February 1995
sampling are in Table 11.
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AfWFrank- ROD
11. Surface water
Unlike the ground water samples, the surface water samples
analyzed contained relatively few organic and inorganic
contaminants. Figure 4, shows the locations for surface water
and sediment sampling during the RI. Tables 12 and 13 present
the organic and inorganic surface water sampling results.
Only sampling location SW-10 and SW-01 were found to contain
organic contaminants. TCE was identified in SW-10 at 39 ppb and
SW-01 which is directly downstream of SW-10 contained TCE at 4
ppb. Sampling location SW-10 was in the location of a spring
which feeds the unnamed tributary of West Valley Creek. It is
believed that the organic sampling results at location SW-10 are
more representative of shallow ground water because the spring in
this location is in the downgradient portion of the Site plume.
The level of TCE found in SW-10 is also comparable to levels
found in nearby residential wells.
The results of the inorganic analyses of surface water
samples show that aluminum is the only metal with a significantly
elevated concentration. Aluminum was found in one filtered
sample at location SW-06 which was a background sample. Three
other unfiltered locations showed elevated aluminum levels, on of
which, SW-09, also was a background sample. It is believed based
on sampling locations and concentrations found that the elevated
aluminum values, are most likely due to suspended clay.
12. Sediment
Figure 4, shows the locations for surface water and sediment
sampling during the RI. Tables 14 and 15 present the organic and
inorganic surface water sampling results.
Results of the organic analyses indicates that 10 out of the
11 sampling locations showed significantly increased
concentrations of PAHs including: phenanthrene, flouranthene,
pyrene, benz(a)anthracene, chrysene, benzo(b)flouranthene,
benzo(k)flouranthene and benzo(a)pyrene. Only sample location
SD-07 did not show levels of PAHs above detection limits.
The results of the inorganic sampling analyses indicates that
concentrations for aluminum as in the surface water sampling
results and lead were detected above background levels. Lead was
found at comparable levels (i.e. less than a factor of 2) ,
however, in all the background samples.
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AIW Frank - ROD
VI. SUMMARY OF SITE RISKS
A baseline Risk Assessment was prepared in order to identify
and define possible existing and future health risks and
potential environmental impacts associated with exposure to the
chemicals present in the various media at the Site if no action
were taken. The baseline Risk Assessment provides the basis for
taking action and indicates the exposure pathways that need to be
addressed by the remedial action. The entire baseline Risk
Assessment can be found in the April 1995 Remedial Investigation
Report for the AIW Frank/Mid-County Mustang Site, Section 6. It
is comprised of 4 parts including: Selection of Chemicals of
Concern (or, Hazard Evaluation); Exposure Assessment, Toxicity
Assessment; and Risk Characterization.
A. H"™an Health Risk Evaluation
1. Selection of Chemicals of Concern
A total of 49 chemicals, including VOCs, semivolatiles,
PAHs, metals and pesticides were detected in the environmental
media sampled during the Remedial Investigation. Although many
of the detected substances were found not to contribute
significantly to overall public health risks, the risk assessment
considered risks from all detected chemicals (i.e. all chemicals
were considered of potential concern). The complete listing of
chemicals of concern can be found in Section 6.1 of the Remedial
Investigation report. The major contaminants of concern are
listed below:
trichloroethene
1,1 dichloroethene
1,1,1 trichloroethane
1,1,2 trichloroethene
. cis 1,2 dichloroethane
chloroform
manganese
Toxicological profiles for the major contaminants of concern can
be found in Appendix C.
2. Exposure Assessment
The objective of the exposure assessment is to estimate the
amount of each chemical of potential concern at a site that is
actually taken into the body (i.e. the intake level or dose).
There are three primary routes through which individuals may be
exposed to site related contaminants: incidental ingestion,
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AIW Frank -ROD
inhalation and dermal contact. The three receptor groups for
which public health risks were evaluated at the site are as
follows: adult .resident, child resident and adult employee.
There are currently no plans to develop the site for residential
use, but because there are currently no prohibitions in place, a
future residential use scenario was considered in the risk
assessment.
Receptors can be either directly or indirectly exposed to
site related contaminants via the four environmental media
addressed in the Remedial Investigation — ground water, surface
water, soils (surface and subsurface) and sediment. Exposure
routes involved include dermal contact, ingestion, and/or
inhalation.
Carcinogenic risks are calculated as an incremental lifetime
risk, and therefore incorporate terms to represent the exposure
duration (years) over the course of a lifetime (70 years, or
25,550 days). Noncarcinogenic risks are calculated using the
concept of an average annual exposure.
Three potential exposure routes are associated with
potential future ground water use in the vicinity of the site.
The exposure routes include ingestion, inhalation of vapors
during showering, and dermal contact. Adult residents are
assumed to ingest 2 liters of water per day, 350 days per year,
over a 30 year exposure duration. Child residents are assumed to
ingest 1 liter of water per day, 350 days per year for six (6)
years. Bodyweights are specified as 70 kg for adults and 15 kg
for children.
Inhalation exposures during showering are estimated using
modeling techniques. The modeling techniques account for
inhalation during showering for adults, as well as, after the
shower while the receptor remains in the room. Dermal exposures
during bathing for children are estimated assuming total body
contact for .2 hours per day, 350 days per year for six years.
Actual current exposure to surface water and sediments
through incidental ingestion, or dermal contact by adolescent
children wading in West Valley Creek were assessed, as well as,
actual current exposure to surface soil through incidental
ingestion or dermal contact by adult or child resident, and
potential future exposure to subsurface soil through incidental
ingestion or dermal contact by adult or child resident.
3. Toxicity Assessment
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AIWFrank -ROD
The toxicity assessment characterizes the inherent toxicity
of a compound and helps to identify the potential health hazard
associated with exposure to each of the chemicals of concern.
Toxicological values, reference doses (RfDs) for non-carcinogenic
chemicals, and the non-carcinogenic effects of carcinogens, and
cancer slope factors (CSFs) for known, suspected, and possible
human carcinogens, derived by USEPA were used in the Risk
Assessment.
RfDs have been developed by EPA for indicating the potential
for adverse health effects from exposure to chemicals exhibiting
noncarcinogenic effects. RfDs, which are expressed in units of
mg/kg-day, are estimates of lifetime daily exposure levels for
humans, including sensitive individuals. Estimated intakes of
chemicals from environmental media (e.g., the amount of a
chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors help
ensure that the RfDs will not underestimate the potential for
adverse noncarcinogenic effects to occur.
CSFs have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic chemicals.
CSFs, which are expressed in units of (mg/kg-day)"1, are
multiplied by the estimated intake of a potential carcinogen, in
mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper-bound" reflects the conservative estimate
of the risks calculated from the CSF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. CSFs
are derived from the results of human epidemiological studies or
chronic animal bioassays to which animal to human extrapolation
and uncertainty factors have been applied.
4. Risk Characterization
The baseline risk assessment in the Remedial Investigation
report quantified the potential carcinogenic and non-carcinogenic
risks to human health posed by contaminants in the various
exposure media. The carcinogenic and non-carcinogenic risks were
determined for ground water, surface water, soils (surface and
subsurface) and sediment.
Carcinogenic risk is presented as the incremental
probability of an individual contracting some form of cancer over
a lifetime as a result of exposure to the carcinogen. For known
or suspected carcinogens, acceptable exposure levels are
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AIW Frank - ROD
generally concentration levels that represent an excess upper
bound lifetime cancer risk to an individual of between 1.0 x 10"4
(or 1 in 10,000), and 1.0 x 10'6 (or 1 in 1,000,000) using
information on the relationship between dose and response. Risk
standards for non-carcinogenic compounds are established at
acceptable levels and criteria considered protective of human
populations from the possible adverse effects from exposure. The
ratio of the average daily doses ("ADD") to the reference dose
("RfD") values, defined as the Hazard Quotient, provides an
indication of the potential for systemic toxicity to occur. To
assess the overall potential for non-carcinogenic effects posed
by multiple chemicals, a Hazard Index ("HI") is derived by adding
the individual hazard quotients for each chemical of concern.
This approach assumes additivity of critical effects of multiple
chemicals. EPA considers any HI exceeding one (1.0) to be an
unacceptable risk to human health. A summary of the risks by
exposure route at the AIW Frank/Mid-County Mustang Site are in
Table 16.
a. Current Use Scenario
* Actual current exposure through inaestion. dermal contact
and inhalation of vapors during showering of ground water
via the existing drinking water wells;
Although several known or potentially carcinogenic chemicals
were detected in the drinking water wells, the excess lifetime
cancer risk estimates for the levels of contaminants detected in
the wells do not exceed the EPA target range of 1.0 x 10"4 (or 1
in 10,000), and 1.0 x 10*6 (or 1 in 1,000,000). However, the
excess lifetime cancer risk estimates for the levels of
contaminants detected in residential wells,. HW-06, HW-10, HW-ll,
HW-12 and HW-13 were all greater than 1.0 x 10'5 (or 1 in
100,000). Hazard quotient/Hazard Indices for scenarios
associated with the current use of drinking water wells exceeded
unity in only one location: HW-10 for both adult (HI = 1.12) and
child residents (HI = 2.10).
* Actual current exposure to surface water through
incidental inaestion. or dermal contact bv adolescent
children wading in West Valley Creek;
The excess lifetime cancer risk estimates for the levels of
contaminants detected in surface water do not exceed the EPA
target range of 1.0 x 10"4 (or 1 in 10,000), and 1.0 x 10'6 (or l
in 1,000,000) and in fact are less than the lower limit of the
EPA risk goal (1 in 1,000,000). Hazard quotient/Hazard Indices
for scenarios associated with the current exposure of adolescents
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AFWFrank -ROD
to surface water do not exceed unity in any instance.
* Actual -current exposure to sediments through incidental
inaestion. or dermal contact by adolescent children wading
in West Valley Creek;
The .excess lifetime cancer risk estimates for the levels of
contaminants detected in sediments do not exceed the EPA target
range of 1.0 x 10~4 (or 1 in 10,000), and i.o x 10"6 (or 1 in
1,000,000). Hazard quotient/Hazard Indices for scenarios
associated with the current exposure of adolescents to sediments
do not exceed unity in any instance.
* Actual current exposure to surface soil through
incidental inaestion or dermal contact by adult or child
resident;
The excess lifetime cancer risk estimates for the levels of
contaminants detected in surface soils do not exceed the EPA
target range of 1.0 x 10'4 (or 1 in 10,000), and 1.0 x 10'6 (or l
in 1,000,000) via ingestion and dermal contact for adult
residents, child resident, or adult employees'. Hazard
Quotient/Hazard Indices for scenarios associated with the current
exposure of adult residents and adult employees to surface soils
do not exceed unity in any instance. However, the Hazard Index
for child residents (1.4) exceeds one (1) for dermal contact
with surface soil. This is primarily due to the child's lower
body weight.
b. Future Use Scenario
* Potential future exposure through inqestion. dermal
contact and inhalation of vapors during showering of ground
water based on the monitoring well analytical results:
The excess lifetime cancer risk estimates for the levels of
contaminants of concern detected in monitoring wells via
ingestion by an adult resident under this scenario exceeds the
EPA target range of 1.0 x 10*4 (or 1 in 10,000) with an estimate
of 8.0 x 10"4 (or 8 in 10,000). The contaminants of concern
contributing most to the excess lifetime cancer risk estimate are
chloroform and 1,1 dichloroethene.
The total Hazard Indices for adult residents exceed one via
ingestion and inhalation of vapors during showering, indicating
that adverse noncarcinogenic health effects may occur if
contaminated ground water is used for domestic purposes some time
in the future. For an adult resident under this scenario the
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AIW Frank -ROD
ingestion HI totalled 35 and the inhalation HI equaled 2.0. The
contaminants of concern contributing most to the Hazard Indices
are cis 1,2 dichloroethane, trichloroethene and manganese.
The excess lifetime cancer risk estimates for the levels of
contaminants of concern detected in monitoring wells via
ingestion by a child resident under this scenario exceeds the EPA
target range of 1.0 x 10~4 (or 1 in 10,000) with an estimate of
1.2. x 10"4 (or 1.2 in 10,000). The contaminants of concern
contributing most to the excess lifetime cancer risk estimate are
1,1 dichloroethene and trichloroethene.
The total Hazard Indices for child residents exceed one for
ingestion, indicating that adverse noncarcinogenic health effects
may occur if contaminated ground water is used for domestic
purposes some time in the future. For a child resident under
this scenario the ingestion HI totalled 81. The contaminants of
concern contributing most to the Hazard Indices are cis 1,2
dichloroethane, trichloroethene and manganese.
* Potential future exposure to subsurface soil through
incidental ingestion or dermal contact by adult or child
resident;
The excess lifetime cancer risk estimates for the levels of
contaminants detected in subsurface soils do not exceed the EPA
target range of 1.0 x 10~4 (or 1 in 10,000), and 1.0 x 10"6 (or l
in 1,000,000) for scenarios associated with the future exposure
of adult residents, child residents and adult employees to
subsurface soils via ingestion and inhalation of fugitive dusts.
However, the excess lifetime cancer risk estimates for the levels
of contaminants detected in subsurface soils do exceed the EPA
target range of 1.0 x 10"4 (or 1 in 10,000), and 1.0 x 10'6 (or l
in 1,000,000) for scenarios associated with the future exposure
of adult residents (2.7 x 10*4) and child residents (3.3 x 10'4)
to subsurface soils via dermal contact. The contaminant of
concern primarily contributing to the excess cancer risk is 1,1
dichloroethene. It should be noted, however, that 1,1 OCE is a
volatile contaminant, which may volatilize rapidly when exposed
to air.
Hazard Quotient/Hazard Indices for scenarios associated with
the future exposure of adult residents, child residents and adult
employees to subsurface soils do not exceed unity for ingestion
or inhalation of fugitive dust. However, the Hazard Index for
adult resident (2.4), child residents (12.5) and adult employees
(1.7) all exceed one (1) for dermal contact with subsurface soil.
The contaminants of concern primarily contributing to the Hazard
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AIW Frank - ROD
Indices are 1,1 dichloroethene, 1,1,1 trichloroethane and 1,1,2
trichloroethene. It should be noted, however, that 1,1
dichloroethene,. 1,1,1 trichloroethane and 1,1,2 trichloroethene
are volatile contaminants, which may volatilize rapidly when
exposed to air.
The principal purpose of the ecological risk assessment is
to determine the likelihood that biological species habitats
in the site area are exposed to unacceptable risks from site
contaminants. The ecological risk assessment consisted of three
primary components; site characterization, exposure assessment,
and risk characterization.
l. site Characterization
The site characterization briefly describes..the major plant
and animal species that were observed or expected to inhabit or
use the site area. The general habitats identified in the site
area include stream and pond habitats for fish, water fowl,
amphibian and other diverse aquatic biota; wetland/swale habitat
for a wid'e range of wetland type bird, vegetation and other
biota; upland habitat for deer, rodents, other mammals and birds.
Observations indicate that some of the potential receptor
wildlife type at the site may include, but not be limited to,
deer, ducks, geese, raccoons, fish, rabbits, small rodents,
raptors, amphibians, and many others.
No Federal listed endangered species are in the vicinity of
the Site, however, it was determined that there.was a possibility
that some State listed/Federal candidate endangered species may
exist in the Site area.
2. Exposure Assessment
The exposure assessment includes estimated environmental
effects quotients ("EEQs") for chemicals in each medium of
concern (i.e. surface water, sediment, etc...). Chemicals of
concern were identified for surface water, and sediments.
Chemicals identified in ground water were not considered in this
assessment because no direct expression of ground water has been
analyzed at the Site. The primary criterion used for verifying
the selection of chemicals of concern was the toxicity for the
specific chemical. The selected benchmark toxicity screening
value for surface water was the chronic ambient water quality
criteria ("AWQC") and for sediment was the effects range low
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AIW Frank -ROD
("ER-L") value.
Primary exposures represent those exposures to chemicals
occur between the contaminated media and the initial biological
receptor. Contaminants have been identified in surface water,
soils and sediment which may facilitate the exposure of the local
biota to chemicals of concern. From these media, possible routes
of entry into biological systems include direct ingestion of
contaminated soils, and water, absorption from contaminated soils
and water, and inhalation of contaminated respirable dusts. In
the case of aquatic organisms, exposure routes include whole body
exposure through dermal absorption, respiration (skin,gills) and
direct ingestion via water or sediment.
Secondary exposure results from the consumption of
contaminated organisms. Through this mechanism, contaminants
move through the food web from one trophic level to another. The
extent to which a contaminant will survive in the biota through
secondary exposure mechanisms is, in part, estimated through the
bioconcentration factor.
3. Risk Characterization
The physical features of the Site indicate that four habitat
types exist on the site. These are wetland/swale. West Valley
Creek and its tributaries, on-site pond and old field habitats.
Fish were observed in the pond. West Valley Creek approximately
1 mile west of the Site is classified as a cold water fishery
trout stream.
Risk characterization involves comparing EEQs for chemicals
to toxic, or hazardous concentration benchmark values. The
following discusses the EEQs (as in the non-carcinogenic human
health risk assessment an EEQ greater than one indicates a
potentially unacceptable ecological risk and some type of action
may be warranted) for water and sediments associated with the
Site.
a. Surface Water
Surface water EEQs were calculated for TCE, heptachlor, lead
and copper. An EEQ greater than one (1) was calculated for both
copper (1.7) and lead (2.13). Neither organic constituent
exceeded an EEQ of one.
b. Sediments
Sediments EEQs were calculated for arsenic, lead,
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AIW Frank -ROD
benzo(a)pyrene and benzo(a)anthracene. An EEQ greater than one
(1) was calculated for arsenic (2.7), lead (1.9) and
benzo(a)pyrene .(1.12).
The EEQs above are suggestive of some potential risk to
ecological receptors, however, the results of the ecological risk
assessment have not provided conclusive evidence that
contaminants originating from the Site have reached any
ecological receptor. However, these results indicate a potential
for ecological receptors to be impacted via contaminated surface
water runoff and contaminated sediment transport from the Site.
A conclusive risk determination can only be made if additional
information is collected and evaluated.
VII. DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES
The Feasibility Study ("FS") Report discusses the alternatives
considered for the cleanup of the contaminants of concern
identified during the RI for the Site and provides supporting
information leading to alternative selection by EPA. The
following presents a summary of the remedial alternatives which
were carried through a detailed analysis in the FS, except where
noted. The alternatives presented below do not directly
correspond with the numbers in the FS, however, EPA believes the
presentation below to be, in general, more easily understandable.
Summary of Alternatives
Alternative 1;
Alternative 2:
Alternative 3:
Alternative 4:
Alternative 5;
NO ACTION
LIMITED ACTIONS
LIMITED ACTIONS/PUBLIC WATER
SUPPLY
GROUND WATER AND SOIL REMEDIATION
GROUND WATER; SOIL REMEDIATION &
PUBLIC WATER SUPPLY
A. DESCRIPTION OF ALTERNATIVES
1. Alternative is HO ACTION
Estimated Capital Costs: $ 0
Estimated Total O&M Costs: $ 0
Estimated 30 Year Total Present Worth Costs:
$ 0
The National contingency Plan ("NCP") requires that EPA consider
a "No Action" alternative for each site to establish a baseline
for comparison to alternatives that do require action. There are
no capital costs or Operation & Maintenance (O&M) costs
associated with this alternative. Under this alternative, no
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AIWFrank- ROD
additional remedial activities or ground water monitoring would
be conducted.
2. Alternative 2: LIMITED ACTIONS, including:
1) Institutional Controls
2) Point of Use Carbon Filtration Units
3) Removal/Excavation and Disposal of Drums and Sump
4) Additional Ecological Assessment
5) Structure Demolition
6) Long Term Ground Water Monitoring
Estimated Capital Costs: $429,000
Estimated Total O&M Costs: $872,000
Estimated 30 Year Total Present Worth Costs: $1,301,000
1) Under this alternative, institutional controls would be
implemented limiting the future use of the property to prevent
human exposure to the soil and ground water contamination
present. Institutional controls in the form of site grading and
fencing would be used to limit access to the Site and the
contaminated surface and subsurface soils therein as well as
reduce the potential for erosion which could lead to contaminated
soils being transported to areas which were previously
uncontaminated. This alternative does not include an active
ground water treatment component.
2) Point of use carbon filtration units would be provided to
residents whose wells have shown levels of contaminants above
MCLs or whose well results show an unacceptable health risk.
3) Four drums in the rear building containing solid materials
with low concentrations of solvents would be removed for off-site
disposal at an appropriate off site RCRA Landfill or facility for
treatment, following sampling and analysis for waste
characterization. The sump located east of the front building
pad also would be excavated. The contents would be sampled and
analyzed for waste characterization prior to treatment and
disposal off-site at an appropriate RCRA permitted facility. The
concrete sump will be sampled and analyzed for wastes
characterization for disposal as debris following the appropriate
determinations under the RCRA land disposal restrictions, 40
C.F.R. § 268.45.
4) The potential presence of Pennsylvania listed endangered
species was identified in the ecological risk assessment in the
RI. A limited additional ecological assessment is needed to
determine the actual presence of State listed endangered species
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AIW Frank- ROD
in the Site area and to better determine the source and potential
ecological impact of PCBs, mercury/ copper, lead, zinc and PAHs
in the soils at the Site.
5) Following finalization of the RI/FS in April, 1995 EPA was
notified of the safety hazard presented by the partial collapse
of the rear building and recent indications of vandalism on Site
by Township authorities. The rear building and associated
structures will pose a safety hazard to EPA personnel during
future site related activities. To eliminate the hazards to EPA
personnel and contractors, as well as, site trespassers, posed by
the structures on Site, the demolition of on site structures
including the rear building and water tower will be part of the
limited actions. Based on the costs of the front building
demolition and the relative size and complexity of the rear
building and water tower demolition, EPA estimates that the
demolition of on site structures would cost $250,000. The
$250,000 costs for building demolition are in addition to the
costs presented above under Alternative 2.
6) Continued monitoring would be conducted to track natural
attenuation and would be used to determine a Site-specific
degradation rate.
Five underground storage tanks ("USTs") containing fuel oil were
identified during the RI. Three of the USTs are on the AIW Frank
property and were used as fuel tanks for the boiler room. Two of
the tanks are located on the Mid-County Mustang portion of the
site and were apparently used for fuel oil storage. The RI did
not clearly determine if the tanks on either property are
currently leaking. A stated earlier, these fuel oil USTs are
specifically excluded from Superfund authority and will not be
addressed in the Superfund actions at the Site. The USTs will be
referred to the appropriate State and Federal programs and will
be addressed under those programs.
The total O&M costs include the following: long term monitoring
of on and off site monitoring wells as well as residential wells
in the area of concern; replacement/regeneration of the point of
use carbon filters at least once per year; and periodic fence
maintenance would need to be conducted. A detailed breakdown of
capital and operation & maintenance costs for each alternative
can be found in the Feasibility Study Report ("FS") . A copy of
the FS can be found in the administrative record in the Site
repositories.
3. Alternative 3: LIMITED ACTIONS/PUBLIC WATER SUPPLY,
including:
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AIW Frank - ROD
1) Institutional Controls
2) Point of use Carbon Filtration Units
(until water line is extended)
3) Removal/Excavation and disposal of drums and sump
4) Additional Ecological Assessment
5) Structure Demolition
6) Long Term Ground Water Monitoring
7) Extension of Water Line
Estimated Capital Costs: $ 2,958,00
Estimated Total O&M Costs: $ 136,000
Estimated 30 Year Total Present Worth Costs: $ 3,101,000
In addition to the Limited Actions described above in Alternative
2, this alternative would provide a permanent source of potable
water to affected and potentially affected residents by extending
a municipal water line to the area in the vicinity of the Site.
The Philadelphia Suburban Water Company currently supplies water
to West Whiteland Township, and has sufficient capacity at this
time to provide water. Under this alternative, a water line
would be installed from the existing water mains on either Route
30 and N. Ship Road or Swedesford Road and N. Ship Road.
Independent connections would then be brought into each of the
affected.or potentially affected residences and businesses. Fire
hydrants would be installed along the line, in accordance with
township fire prevention code. Only those users currently
impacted or potentially impacted by the contamination in the
ground water would be connected to the municipal water system.
At this time approximately 12 residences and businesses,
primarily along Exner Lane and N. Ship Road are considered
affected or potentially affected. A final determination
concerning which wells may be potentially impacted would be made
in the future based on all information in EPA's possession at the
time of implementation. As described above under Alternative 2,
point of use carbon filtration units would be provided to
residents whose wells have shown levels of contaminants above
MCLs or whose well results show an unacceptable health risk until
the water line is completed.
The O&M costs of this alternative are associated with the Limited
Actions portion of this alternative and include the following:
long term monitoring of on and off site monitoring wells as well
as residential wells in the area of concern;
replacement/regeneration of the point of use carbon filters at
least once per year during the time the water line has not been
completed; and periodic fence maintenance would need to be
conducted if structure demolition is not chosen under limited
actions.
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ALTERATIVES 4 £ 5
4. Common Components of Alternatives 4 & 5
a. Soil Investigation
Alternatives 4 and 5 will each include a soil investigation to
determine more accurately the areal and volumetric extent of
subsurface soil VOC contamination. Also, additional soil and
sediment sampling will be conducted in the on-site drainage ditch
and behind the rear building to determine the source and extent
of contamination which may be capable of causing adverse
ecological effects as described under Alternative 2, 4)Additional
Ecological Assessment above. The sampling results from the
drainage ditch and from behind the rear building will be used to
determine if additional soil excavation, or grading is necessary
to prevent ecological receptors at the Site from being adversely
affected.
b. Ground Water Pre-Design Study
All of the ground water treatment options under Alternatives 4 &
5 will be designed to reduce or remove the Site related VOCs in
the extracted ground water, unattended, on a continuous, 24 hour-
per-day performance basis. The ultimate objective of these
ground water pump and treat alternatives is to restore the
contaminated ground water plume to MCLs. The approximate areal
extent of the ground water plume is illustrated in Figures 13, 14
& 15. [See Section V.B.9. for more detailed information on extent
the ground water contamination.]
The proposed plan estimated a total system pumping rate of 300
gallons per minute ("gpm"), which would capture the estimated
ground water plume. However, based on comments received during
the public comment period, EPA conducted a more detailed site
specific design evaluation of the number of wells and total
pumping rate which would capture the ground water plume. As a
result, EPA now estimates that the combined recovery well pumping
rate that will capture the estimated ground water contaminant
plume is approximately 150 gallons per minute ("gpm") . All the
treatment systems will be designed to handle raw ground water at
a rate of approximately 225 gpm. The systems will also have the
flexibility to respond to varying concentrations and flow rates.
The alternatives involving effluent discharge to West Valley
Creek, a tributary of Brandywine Creek, will be designed to
remove greater than 99% of the VOCs in order to comply with the
PADEP's discharge requirements.
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RI data indicates that arsenic concentrations nay exceed the
PADEP discharge requirements for West Valley Creek, therefore, if
after further study during the remedial design, data continues to
indicate that arsenic will exceed the effluent discharge
requirements, the system will be designed such that raw water
will be treated by coagulation/flocculation-precipitation to
remove principally iron and manganese which will result in the
co-precipitation of arsenic. This is currently the best
available economically feasible technology for arsenic removal.
However, if in the future another arsenic removal technology
becomes available that will achieve the required PADEP NPDES
discharge limits more economically it will be considered. If
variations occur, such as increased contaminant concentration or
increased flow rate, the selected system may not be capable of
attaining the required effluent concentration limits. Options to
address these potential variations will be evaluated as necessary
during the detailed system design. Arsenic removal is not
expected to be necessary in the alternatives with discharge to
the POTW. The systems involving discharge to the POTW will
comply with the Clean Water Act (33 U.S.C. §§1251 et sea.)
General Pretreatment Regulations for Existing and New Sources of
Pollution, as set forth at 40 CFR Part 403. However, RI water
quality data indicates that pretreatment will not be warranted.
In addition to the above, all of the ground water treatment
options under Alternatives 4 & 5 will require the following:
l) the performance of a hydrogeologic investigation
including aquifer pumping tests and sampling to further
delineate the vertical boundaries of the contaminated ground
water plume; the presence of any potential Dense Non-Aqueous
Phase Liquid ("DNAPL") contaminant source (See Section
V.B.9. above for DNAPL discussion); and provide sufficient
data to design an extraction system that will meet the
objective to restore the contaminated ground water to MCLs;
2) abandonment of wells, in accordance with Commonwealth and
local requirements, which serve no useful purpose in order
to eliminate the possibility of these wells acting as a
conduit for future ground water contamination;
3) performance of a Phase I archeological survey prior to
any intrusive remedial activities;
4) periodic monitoring of ground water to determine the
effectiveness of the selected ground water treatment
alternative.
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AIW Frank - ROD
5. Alternative 4: GRODHD WATER AMD SOIL REMEDIATION
Alternative 4 below includes Alternative 2 and the common
components described immediately above; plus, In-situ soil
remediation and ground water extraction and treatment, as
follows:
1) Institutional Controls
2) Point of use Carbon Filtration Units
3) Removal/Excavation and disposal of drums and sump
4) Additional Ecological Assessment
5) structure Demolition
6) Long Term Ground water Monitoring
7) Soil Investigation
8) Ground Water Pre-Design Study
9) In-situ vapor extraction and carbon adsorption
10) Ground water extraction and treatment via either
air stripping, or granular activated carbon ("GAG")
with discharge to West Valley Creek, or POTW.
Items 1) through 6) are described under Alternative 2 above.
Items 7) & 8) are described in Subsections 4 (a) & 4(b).
Item 9) In-situ vapor extraction and carbon adsorption, as
follows.
Estimated Capital Costs: $ 177,000
Estimated Total O&M Costs: $ 279,000
Estimated 30 Year Total Present Worth Costs: $ 456,000
Vacuum Extraction ("VE11) is an in-situ process that requires
minimal site disturbance prior to and during implementation.
Under this alternative, VE wells would be installed to
approximately 20 feet below grade in the area of concern. The
wells would be connected to a vacuum. The VOCs in the subsurface
soil would volatilize and be drawn to the extraction wells
because of the induced vacuum. The vapor discharge from the VE
system would pass through an off-gas vapor phase granular
activated carbon ("GAG") treatment unit, to reduce contaminant
concentrations in the air stream to allowable levels prior to
discharge to the atmosphere. Discharge rates and VOC extraction
concentrations would be monitored weekly for two months then
monthly thereafter for two years or until the VOC concentrations
being extracted are below the soil clean up standards. The soil
clean up standards are set forth in Section IX.B.2.b.2. of this
Record of Decision. The total O&M costs include the following:
periodic air sampling to ensure compliance with air quality
standards; At least two years of sampling to determine
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ATW Frank - ROD
achievement of performance standards; periodic VE extraction well
maintenance would be required; and periodic
replacement/regeneration of the vapor phase carbon filtration
unit in accordance with applicable regulations would be reguired.
Item 10) Ground water Extraction and Treatment, could be any
one of toe following (A,B,C, or D):
A. Ground water extraction and treatment (airstripping with
vapor-phase carbon adsorption) with discharge to west Valley
Creek;
Estimated Capital Costs: $2,380,000
Estimated Total O&M Costs: $5,153,500
Estimated 30 Year Total Present Worth Costs: $7,533,500
This alternative involves ground water extraction and
treatment of the contaminated ground water by air stripping. The
air stripping system would include a treatment building, controls
and an air stripper tower with a blower, discharge pump,
instrumentation and controls. The air and VOCs exiting the air
stripping column would be treated by a vapor phase carbon
adsorption unit. The treatment building would have space
reserved for additional process equipment as needed. Ground
water would be pumped from the extraction wells through buried
pipelines to the ground water pre-treatment system for arsenic
removal, if necessary, then to the air stripper tower. The
ground water would be introduced at the top of the tower, and
would flow countercurrent to a clean air stream introduced at the
base of the stripping tower. The effluent from the tower would
be discharged to West Valley Creek, a tributary of Brandywine
Creek. The tower would be designed to remove VOCs from the
ground water so that effluent discharge would comply with PADER's
NPDES effluent limitations for discharge to West Valley Creek.
Long term ground water monitoring would be required. The total
O&M costs include the following: periodic maintenance of the pre-
treatment system and air stripper system, periodic
replacement/regeneration of the vapor phase carbon filtration
unit in accordance with applicable regulations, periodic
extraction well maintenance, and long term sampling and analysis
costs.
B. Ground water extraction and treatment (liquid-phase
carbon adsorption) with discharge to West Valley Creek;
Estimated Capital Costs: $ 2,247,000
Estimated Total O&M Costs: $10,075,000
Estimated 30 Year Total Present Worth Costs: $12,322,000
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AIW Frank - ROD
This alternative involves ground water extraction and a
system to treat contaminated ground water with liquid phase
carbon adsorption. The adsorbent would be granular activated
carbon ("GAG") .' The carbon adsorption system would include a
treatment building, controls and two liquid phase carbon
filtration units in series. Ground water would be pumped from
the extraction wells through buried pipelines to the ground water
pre-treatment system for arsenic removal, if necessary. Effluent
from the pretreatment system would be applied directly to the top
of the lead carbon unit and would flow through the unit under
pressure. Effluent from the lead carbon unit would then be
applied to the top of the second adsorption unit. Effluent from
the final GAC unit would be discharged to West Valley Creek. The
liquid phase carbon filtration system would be designed to remove
VOCs from the ground water so that effluent discharge would
comply with PADER's NPDES effluent limitations for discharge to
West Valley Creek. Long term ground water monitoring would be
required. Spent carbon units would be shipped offsite
approximately once per year for regeneration/disposal in
accordance with applicable laws and regulations. The total O&M
costs include the following: periodic maintenance of the pre-
treatment system, periodic replacement/regeneration carbon
filtration units in accordance with applicable regulations,
periodic extraction well maintenance, and long term sampling and
analysis costs.
C. Ground water extraction and treatment (airstripping with
vapor-phase carbon adsorption) with discharge to POTW;
Estimated Capital Costs: $1,800,000
Estimated Total O&M Costs: $12,218,000
Estimated 30 Year Total Present Worth Costs: $14,018,000
This alternative involves ground water extraction and
treatment of the contaminated ground water by air stripping. The
air stripping system would include a treatment building, controls
and an air stripper tower with a blower, discharge pump,
instrumentation and controls. The air and VOCs exiting the air
stripping column would be treated by a vapor phase carbon
adsorption unit. The treatment building would have space
reserved for additional process equipment as needed. Ground
water would be pumped from the extraction wells through buried
pipelines to the air stripper tower. The ground water would be
introduced at the top of the tower, and would flow countercurrent
to a clean air stream introduced at the base of the stripping
tower. Effluent from the tower would be discharged to the local
POTW. The tower would be designed to remove VOCs from the ground
water so that effluent discharge would comply with POTW discharge
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AIW Frank - ROD
permit requirements. Long term ground water monitoring would be
required. The total O&M costs include the following: periodic
maintenance of .the pre-treatment system and air stripper tower,
periodic replacement/regeneration of the vapor phase carbon
filtration unit, periodic extraction well maintenance, POTW sewer
usage charge and long term sampling and analysis costs.
D. Ground water extraction and treatment (liquid-phase
carbon adsorption) with discharge to POTW;
Estimated Capital Costs: $1,670,000
Estimated Total O&M Costs: $17,751,000
Estimated 30 Year Total Present Worth Costs: $19,421,000
This alternative involves ground water extraction and a
system to treat contaminated ground water with liquid phase
carbon adsorption. The adsorbent would be granular activated
carbon ("GAG"). The carbon adsorption system would include a
treatment building, controls and two liquid phase carbon
filtration units in series. Ground water would be pumped from
the extraction wells through buried pipelines to the ground water
pre-treatment system consisting of sand filters for solids
removal. Effluent from the pretreatment system would be applied
directly to the top of the lead carbon unit and would flow
through the unit under pressure. Effluent from the lead carbon
unit would then be applied to the top of the second adsorption
unit. Effluent from the final GAC unit would be discharged to
the local POTW. The liquid phase carbon filtration system would
be designed to remove VOCs from the ground water so that effluent
discharge would comply with POTW discharge permit requirements.
Long term ground water monitoring would be required. Spent
carbon units would be shipped offsite approximately once per year
for regeneration/disposal in accordance with applicable
regulations. The total O&M costs include the following: periodic
maintenance of. the pre-treatment and carbon filtration systems,
periodic replacement/regeneration carbon filtration units in
accordance with applicable regulations, periodic extraction well
maintenance, POTW sewer usage charge and long term sampling and
analysis costs.
6. Alternative 5: GRODHD WATER; SOIL REMEDIATION i PUBLIC
WATER SUPPLY
Alternative 5 described below includes the Limited Actions
of Alternative 2 and common components described above in
Subsections 4(a) & 4(b); soil excavation and off site
disposal; ground water extraction and treatment, and
extension of a waterline, as follows:
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AIW Frank - ROD
1) Institutional Controls
2) Point of use Carbon Filtration Units
(until water line is extended)
3) Removal/Excavation and disposal of drums and sump
4) Additional Ecological Assessment
5) Structure Demolition
6) Long Term Ground Water Monitoring
7) Soil Investigation
8) Ground Water Pre-Design Study
9) Soil excavation and off site disposal
10) Ground water extraction and treatment via either
air stripping, or granular activated carbon ("GAC")
with discharge to West Valley Creek, or POTW
11) Extension of waterline.
Items 1) through 6) are described under Alternative 2 above.
Items 7) & 8) are described in Subsections 4 (a) & 4 (b) . Item 10)
is described immediately above and 11) is described under
Alternative 3 above.
Item 9) Excavation, off-site treatment/disposal of soil and
buried wastes, as follows.
Estimated Capital Costs: $ 513,000
Estimated Total O&M Costs: $ 0
Estimated 30 Year Total Present Worth Costs: $ 513,000
This Alternative entails the excavation and off-site
treatment and disposal of soil contaminated with volatile organic
compounds ("VOCs") including TCE and 1,1,1 TCA at a RCRA Subtitle
C hazardous waste landfill in accordance with the substantive
requirements of the relevant and appropriate regulations. All
soil containing soil contaminants of concern with concentrations
higher than the clean-up standards would be included in the
excavation and disposal. The soil contaminants of concern are
listed in the soil excavation performance standard section pf the
Selected Remedy section of this Record of Decision. Currently,
the estimated volume of soil which would be excavated is 232
cubic yards. This is based on the results of soil and subsurface
sampling during the RI. However, the final volume of soils to be
excavated would be further delineated following additional soil
and subsurface soil sampling. As the excavation occurs, the
material would be sampled until the results indicate that the
soils do not contain the contaminants of concern above clean up
standards. Once the excavation is complete, additional clean
borrow material would be brought in to restore the excavation to
original grade. Under this Alternative no operation &
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maintenance would be necessary.
The limited actions, common components, ground water
treatment options and waterline extension evaluated under
Alternative 5 are identical to those summarized under
Alternatives 2, 3 and 4, respectively. Please refer to the
Alternative summaries above for a summary of each option.
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Each of the remedial alternatives described above were
evaluated using nine criteria. The resulting strengths and
weaknesses of the alternatives were then weighed to identify the
alternative providing the best balance among the nine criteria.
These nine criteria are:
Threshold Criteria
Overall protection of human health and the environment
Compliance with applicable or relevant and appropriate
requirements (" ARARs")
Primary Balancing Criteria
Reduction of toxicity, mobility or volume
Implementabi1i ty
- Short-term effectiveness
- Long-term effectiveness and permanence
Cost
Modifying Criteria
State acceptance
- Community acceptance
A primary requirement of CERCLA is that the selected
remedial action be protective of human health and the
environment. A remedy is protective if it eliminates, reduces or
controls current and potential risks posed through each exposure
\pathway to acceptable levels through treatment, engineering
controls, or institutional controls.
Alternative 1 (No Action) will not protect human health or
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the environment. Alternative 2 (Limited Actions) will to a
limited extent prevent human exposure to Site soil and ground
water contaminants, but will not actively reduce the contaminants
in the soil or ground water or prevent migration of contaminated
ground water. Alternative 3 will provide a permanent alternative
water supply to affected residences and businesses which will
prevent human exposure to ground water contaminants, however, it
will provide only limited reduction in human exposure to Site
soils and will not actively reduce the contaminants in the soil
or ground water, or prevent migration of contaminated ground
water. All of the ground water options under Alternatives 4 and
•5 would prevent migration of and remove contaminants in the
ground water system. The soil vapor extraction soil remediation
under Alternative 4 may not be effective in the clay soil
environment found at the Site. The excavation and off site
disposal/treatment of site soils under Alternative 5 will
effectively and permanently protect against risks posed by Site
soils. Only Alternative 5 will permanently prevent human
exposure to Site ground water contaminants, and.prevent migration
of contaminants in the ground water system in addition to
actively, effectively and permanently removing contaminants from
soil and ground water.
B. Compliance with ARARs
Section 121(d) of CERCLA requires that remedial actions at
CERCLA sites at least attain legally applicable or relevant and
appropriate Federal and State standards, requirements, criteria
and limitations which are collectively referred to as "ARARs",
unless such ARARs are waived under CERCLA Section 121(d)(4).
Applicable requirements are those substantive environmental
requirements, criterias, or limitations promulgated under Federal
or State laws that specifically address hazardous substances
found at the site, the remedial action to be implemented at the
site, the location of the site, or other circumstances present at
the Site.
Relevant and appropriate requirements are those substantive
environmental protection requirements, criteria, or limitations
promulgated under Federal or State law which, while not
applicable to the hazardous materials found at the site, the
remedial action itself, the site location or other circumstances
at the site, nevertheless address problems or situations
sufficiently similar to those encountered at the site that their
use is well suited to the site. ARARs may relate to the
substances addressed by the remedial action (chemical-specific),
to the location of the site (location specific), or the manner in
which the remedial action is implemented (action-specific).
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In addition to applicable or relevant and appropriate
requirements, the lead agencies may, as appropriate, identify
other advisories, criteria, or guidance to be considered for a
particular release. The "to be considered" ("TBC") category
consists of advisories, criteria, or guidance that were developed
by EPA, other federal agencies or states that may be useful in
developing CERCLA remedies. [A detailed listing of ARARs for the
Selected Remedy is in Section X.B. of this Record of Decision.]
The concentrations of VOCs currently in the ground water
exceed Maximum Contaminant Levels in the Safe Drinking Water Act.
Once ground water treatment "is implemented, remediation of ground
water to levels that meet Federal and State ARARs will be
required. All Ground water remediation options under
Alternatives 4 and 5 will comply with all applicable or both
relevant and appropriate federal and State environmental
regulations. The soil remediation under both Alternative 4 and
5 will comply with all ARARs. Alternatives 2 and 3 would not
attain ground water Maximum Contaminant Levels ("MCLs") which are
enforceable, health based drinking water standards established
under the Safe Drinking Water Act. Under Alternative 1, no
actions would be taken, therefore, no ARARs would be attained.
This evaluation criterion addresses the degree to which a
technology or remedial alternative reduces toxicity, mobility or
volume of hazardous substances.
Alternative 1 provides no_reduction in toxicity, mobility or
volume of Site contaminants. Alternatives 2 and 3 provide only
limited reduction in the mobility of surface soil contamination
through grading to prevent surface erosion, however, neither
provide any reduction in toxicity, or volume of Site
contaminants. Alternatives 4 and 5 include recovery and
treatment of the contaminated ground water and either on or off
site treatment and disposal of contaminated soils and will
therefore, significantly reduce the toxicity, mobility and volume
of the contaminants of concern by removing them.
D. ImplementabilitY
Implementability refers to the technical and administrative
feasibility of a remedy, from design through construction,
operation and maintenance. It also includes coordination of
federal, State, and local governments to clean up the Site.
All of the actions under Alternative 2 are easily
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implementable. Alternative 3 would use standard engineering
construction techniques and materials that have been used for
many similar public water extensions, therefore, it should be
readily implementable. Sufficient information is currently
available for preliminary sizing of the extraction and treatment
systems' components; however, these components are subject to
modification during the final design of the ground water options
under Alternatives 4 and 5. Ground water extraction using
recovery wells and treatment by air stripping and GAC are proven
technologies for treating contaminated ground water. The
implementability of the Alternative 4 and 5 ground water options
including discharge to POTW is contingent on the POTW accepting
the extracted ground water. Based on the uncertainties
surrounding potential future POTW requirements regarding volume
and pretreatment, these options are not as easily implemented as
options including discharge to West Valley Creek, and depending
on the capacity at the POTW, may not be implementable. Soil
vapor extraction called for under Alternative 4 to remediate
soils may not be implementable in the clay and mixed waste
subsurface soil environment present at the Site. Soil excavation
and off site treatment/disposal called for under Alternative 5 is
a proven technology which has been implemented at numerous other
Superfund sites and is easily implementable.
E. Short-Term Effectiveness
Short-term effectiveness addresses the period of time needed
to achieve protection of human health and the environment and any
adverse impacts that may be posed during the construction and
operation period until performance standards are achieved.
Alternative 1 will have no short-term impacts. Alternatives
2,4 and 5 all have similar short-term impacts related to dermal
hazards associated with workers contacting either on site soils
or the contaminated ground water, physical hazards associated
with installing the recovery systems and effluent distribution
piping, physical hazards during soil excavation and potential
hazards to on site personnel. Potential dermal contact hazards
can be minimized using appropriate personal protective equipment
when contact with on site soils or contaminated ground water is
possible. Alternative 3 will have those short-term impacts
associated with installation of the water line including possible
temporary disruption of traffic on Route 30, N. Ship Road, or
Exner Lane and physical hazards to workers during excavations for
the main.
P. Long-Term Effectiveness and Permanence
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Long-term effectiveness and permanence refers to the ability
of the remedy to maintain reliable protection of human health and
the environment over time. This evaluation criterion includes
the consideration of residual risk and the adequacy and
reliability of controls.
Alternatives 1, 2 and 3 will not actively reduce contaminant
concentrations in the soil or ground water at the Site. However,
natural attenuation, dispersion, and degradation could result in
a decrease in contaminant concentrations over time. Under
Alternative 1 potential risks associated with ingestion of the
contaminated ground water will continue until the natural
degradation process is complete, if ever. Alternative 2 will
provide limited protection against human exposure to ground water
contaminants through deed restrictions prohibiting ground water
use and point of use carbon filtration units. Alternative 3 will
permanently protect against human exposure to contaminated ground
water. Neither Alternative 2 or 3 effectively addresses the soil
contamination at the Site. The soil vapor extraction soil
remediation under Alternative 4 may not be effective in the clay
and mixed waste environment found at the Site. The excavation and
off site disposal/treatment of site soils under Alternative 5
will effectively and permanently protect against risks posed by
Site soils. The effectiveness of Alternatives 4 and 5 ground
water options will depend on the actual flow and chemical
characteristics of the final recovered ground water and the
discharge requirements for the selected system. The ground water
recovery system would effectively control the migration of ground
water contaminants. Its effectiveness in removing contaminants
to MCLs will be highly dependent on the characteristics of the
aquifer, and the rate of contaminant desorption from the aquifer
matrix. Alternative 5 permanently protects against human
exposure to contaminated ground water by providing affected
residents and businesses with a public water supply in addition
to actively removing contaminants from on site soils and
restoring ground water to MCLs.
6. C08t
This criterion examines the estimated costs for each
remedial alternative evaluated in the Feasibility Study Report.
A summary comparison of capital, O&M, and Present Worth costs for
each alternative are presented in Table 17. Detailed alternative
cost estimates can be found in Appendix D of this Record of
Decision.
Alternative 1 is obviously the least expensive option,
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however/ no actions to remediate the contamination at the Site
would be taken. Alternative 2 is less expensive than Alternative
3, however, Alternative 3 provides a permanent potable water
supply to affected residences and businesses while also including
the limited actions of Alternative 2. Alternatives 4 and 5 are
substantially more expensive than Alternative 2 or 3.
Alternative 5 is the most expensive in general because it
includes costs for the public water supply and limited actions as
well as soil and ground water remediation. The range of costs
indicated for the ground water options under Alternatives 4 and 5
is attributable to the differences in costs between the two
ground water treatment options (air stripping vs. GAG filtration)
and between the two ground water discharge options (West Valley
Creek vs. POTW).
Of the ground water options in Alternatives 4 and 5, liquid-
phase carbon treatment is more expensive than air stripping with
vapor-phase carbon treatment, because considerably less carbon
would need to be maintained for the air stripping vapor-phase
system while removing the same quantity of VOCs over the life of
the system.
Discharge to a POTW as described in the proposed plan will
be considerably more expensive than discharge to surface water
unless arsenic removal costs become prohibitive. The POTW would
charge a significant discharge fee that would not be an expense
incurred for discharge to West Valley Creek or other surface
water. For soil treatment, in situ vapor extraction is slightly
less expensive than off site treatment and disposal, however, off
site treatment and disposal does not require any pilot testing or
operation & maintenance. Also, soil vapor extraction may not be
effective in the clay and mixed waste environment found at the
Site. Appendix D provides detailed cost breakdowns for each
alternative.
H. State Acceptance
PADEP has assisted EPA in the review of reports and Site
evaluations. The Commonwealth of Pennsylvania Department of
Environmental Protection agrees with the approach of EPA's
Selected Remedy as described in the Declaration above.
X* <"?«ninr»in xty Acceptance
A public meeting on the Proposed Plan was held on June 16,
1995 at the West Whiteland Township building in Exton, West
Whiteland Township, Pennsylvania. Comments received orally at
the public meeting and in writing during the public comment
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period are referenced in the Responsiveness Summary attached to
this Record of Decision.
The vast majority of comments received focused on the
proposed treated water discharge to West Valley Creek. EPA's
detailed responses to the comments received are in the
Responsiveness Summary, as mentioned above, and a detailed
discussion of the changes made in the Selected Remedy after
consideration of the comments received are in the Documentation
of Changes from Proposed Plan, Section XI of this Record of
Decision below.
EPA's Selected Remedy includes a component for discharge of
treated effluent water. EPA retains the discretion, as part of
the Remedy, to utilize any one (or a combination) of three
identified discharge locations: 1) discharge to West Valley
Creek as described in the proposed plan, 2) discharge to the on
site pond, or 3) discharge to the proposed West Whit eland spray
irrigation POTW. EPA has concluded that each of..these locations
is appropriate under the NCP. The decision as to which discharge
option will be implemented will be made during the remedial
design in consultation with the Commonwealth of Pennsylvania.
EPA will keep citizens informed of the discharge location
selection process through distribution of fact sheets and
periodic public meetings during the remedial design.
In summary, the Selected Remedy is believed to provide the
best balance of trade-offs among the alternatives evaluated with
respect to the nine criteria above. Based on the information
available at this time, EPA believes the Selected Remedy will
protect human health and the environment, will comply with ARARs
and be cost-effective. In addition, permanent treatment options
would be utilized to the maximum extent practicable.
IX. THE SELECTED REMEDY; DESCRIPTION, PERFORMANCE STANDARD(8)
AND COSTS FOR EACH COMPONENT OF THE REMEDY
A. General Description of the Selected Remedy
EPA carefully considered state and community acceptance of the
remedy prior to reaching the final decision regarding the remedy.
The Agency's preferred remedy is set forth below. Based on
current information, this alternative provided the best balance
among the alternatives with respect to the nine criteria EPA uses
to evaluate each alternative. The selected remedy consists of
the following components:
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1. Extraction and treatment via air stripping of
groundwater with vapor phase carbon adsorption and
subsequent discharge to either: 1) West Valley Creek,
2) the on site pond, or 3) West Whit eland spray
irrigation POTW, following a predesign hydrogeologic
investigation;
2. Excavation and off-site disposal of contaminated soils,
following predesign soil investigations;
3. Installation of a water line;
4. Removal, decontamination and off-site disposal of drums
and sump;
5. Structure Demolition/Restoration
6. Institutional controls
7. Performance of an Additional Ecological Assessment;
8. Provision of Point of Use Carbon Filtration Units
(until waterline is extended)
9. Performance of a Phase I archeological survey prior to
any intrusive remedial activities.
10. Long Term Ground Water Monitoring.
Each component of the Selected Remedy and its Performance
Standards and Costs are described below.
B. Description* Performance standard (a) and Costs of Each
Component of the Selected Remedy
1. Extraction and Treatment via Air Stripping of
Groundwater vith Vapor Phase Carbon Adsorption and
subsequent discharge to either: 1) West Valley Creek,
2) the On Site Pond, or 3) west Whiteland Spray
Irrigation POTW, following a predesign hydrogeologic
investigation;
l.a. Description
The groundwater shall be remediated through extraction and
treatment via air stripping with vapor phase carbon
adsorption throughout the area of the contaminant plume.
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The treated groundwater effluent will be discharged to
either West Valley Creek, the on-site pond, or the proposed
West Whiteland spray irrigation POTW. The spent carbon from
the vapor phase carbon units will be sent off site
periodically for regeneration or disposal.
l.b. Performance standards
l.b.l. Extraction wells shall create groundwater capture
zones where the contaminated groundwater is hydraulically
contained and shall prevent migration beyond the existing
plume area. The exact number and location of extraction
wells will be determined during the remedial design phase.
The extent of the groundwater plume shall be fully
determined through the use of monitoring wells. The
performance of the extraction and treatment system shall
also be monitored through use of monitoring wells. EPA, in
consultation with the Commonwealth of Pennsylvania, will
determine if additional monitoring wells are necessary to
determine the extent of the ground water plume or
performance of the system.
l.b.2. At least one round of samples shall be collected
from existing Site monitoring wells as well as any
additional monitoring wells installed, during the predesign
phase, and analyzed for volatile organic compounds, in order
to determine the extent of the groundwater contaminant plume
at that time.
l.b.3. Aquifer pumping tests shall be performed during the
predesign phase in order to define aquifer characteristics
and determine possible dewatering effects, if any, the
extraction system may have on the on site jurisdictional
wetlands. Figure 16 shows the location of the
jurisdictional wetlands area. If dewatering occurs and
affects any endangered species or their habitat, a
consultation will be made with the Commonwealth of
Pennsylvania and the U.S. Fish & Wildlife Service regarding
mitigation.
l.b.4. Groundwater shall be treated using an on site air
stripping treatment system. The treatment system shall
reduce the Site-related contaminants in the extracted
groundwater, unattended, on a continuous, 24-hour-per-day
performance basis.
l.b.5. A system to treat contaminated groundwater via
airstripping with vapor phase carbon adsorption shall
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AIW Frank -ROD
achieve 99% (percent) removal of VOCs in compliance with the
substantive requirements of PADEP's NPDES regulations for
discharge to surface water, or with the federal Clean Water
Act (33 U.'S.C. §§1251 et seq.) pretreatment regulations for
existing and new sources of pollution as set forth at 40 CFR
Part 403, if discharged to the West Whiteland spray
irrigation POTW. The final combined pumping rate and the
exact location, size, and number of wells shall be based on
the ability to hydraulically control the contaminated
groundwater plume. Final flow rates and air stripper system
dimensions will be determined by EPA in consultation with
PADEP during remedial design.
l.b.6. If during predesign, arsenic is detected above the
NPDES discharge requirements for the Site, the system shall
co-precipitate arsenic from the groundwater prior to
entering the air stripper system. The current best
available technology for arsenic removal from groundwater is
co-precipitation during coagulation and flocculation
precipitation of the groundwater for iron and manganese
removal.
l.b.7. The treated groundwater effluent will be discharged
to either West Valley Creek, the on-site pond, or the
proposed West Whiteland spray irrigation POTW, following
predesign investigation of the treatment system flow
capacity, substantive NPDES requirements, or POTW
pretreatment requirements, and further determination of any
potential adverse effects of the on site drainage ditch or
dewatering of on site wetlands to ecological receptors. The
discharge point shall be the location that best protects
human health and the environment, considering the identified
factors and cost and implementability. Treated effluent
will be discharged through a new outfall, or through a
piping system if spray irrigation through the POTW is
implemented, that shall be constructed as part of the
remedial action.
l.b.8. The extraction and treatment system shall avoid,
minimize and mitigate impacts on floodplains and wetlands
(e.g., dewatering wetlands, discharge to either West Valley
Creek, the on site pond or connection to the West Whiteland
spray irrigation POTW). The performance standard will be
compliance with Executive Order No. 11988 and 40 CFR Part 6,
Appendix A (regarding avoidance, minimization and mitigation
of impacts on floodplains), and Executive Order No. 11990
and 40 CFR Part 6, Appendix A (regarding avoidance,
minimization and mitigation of impacts on wetlands).
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l.b.9. An operation and maintenance plan shall be developed
for the groundwater extraction system during the remedial
design phase. The operation and maintenance plan shall be
developed 'and implemented to determine the operation and
performance of the system within design criteria and
achievement of performance standards. At a minimum, the
influent and effluent from the treatment facility shall be
sampled twice per month for volatile organic compounds.
Operation and maintenance of the groundwater extraction
system shall continue for an estimated 30 years or such
other time period as EPA, in consultation with the
Commonwealth of Pennsylvania, determines to be necessary,
based on the statutory reviews of the remedial action which
shall be conducted no less often than every five years from
the initiation of the remedial action in accordance with the
EPA guidance document, Structure and Components of Five-Year
Reviews (OSWER Directive 9355.7-02, May 23, 1991). 5-year
statutory reviews under Section 121(c) of CERCLA will be
required, as long as hazardous substances remain onsite and
prevent unlimited use and unrestricted access to the Site.
The performance of the ground water extraction and treatment
system shall be carefully monitored on a regular basis, as
described in the long-term ground water monitoring component
of this Selected Remedy. The system may be modified, as
warranted by the performance data collected during operation
to achieve Performance Standards. These modifications may
include, for example, alternate pumping of the extraction
well(s) and the addition or elimination of certain
extraction wells.
l.b.10. The operation and maintenance plan shall be revised
after construction of the collection system has been
completed if it is determined to be necessary by EPA. .
l.b.ll. Neither the extraction system nor discharge of
treated ground water shall adversely affect the thermal
regime of West Valley Creek. A comprehensive analysis of
the groundwater extraction system shall be made prior to
implementation to determine the thermal effects the system
may have on West Valley Creek. West Valley Creek will be
monitored downstream of any discharge to ensure the
requirements of Pennsylvania Water Quality standards 25 Pa.
Code Section 93.7 are maintained. The analysis shall
include establishment of West Valley Creek background
conditions, and modeling of the background data to
demonstrate the thermal effects of any dewatering of
affected feeder springs and the discharging of the treated
effluent. The establishment of background conditions for
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West Valley Creek shall include, at a minimum, temperature
and flow readings from downstream locations, the exact
number and locations to be determined during the remedial
design in'consultation with the Commonwealth of
Pennsylvania. The exact frequency and duration of
measurements and methods to be used also, will be determined
by EPA, in consultation with the Commonwealth of
Pennsylvania, during the remedial design phase. The
analysis shall include, if necessary, mitigation plans for
maintaining the background thermal regime of West Valley
Creek.
l.b.12. Existing pumping and monitoring wells which serve no
useful purpose shall be properly plugged and abandoned
consistent with PADEP's Public Water Supply Manual, Part II,
Section 3.3.5.11 and Chester County Health Department Rules
and Regulations Chapter 500, in order to eliminate the
possibility of these wells acting as a conduit for future
groundwater contamination. Wells which EPA.determines are
necessary for use during the long term monitoring program
will not be plugged.
l.b.13. The ground water plume shall be pumped and treated
until the Maximum Contaminant Level ("MCL") or the non zero
MCLG for the contaminants of concern [40 C.F.R. part 141]
whichever is more stringent is achieved.
The performance standard for major contaminants of concern
in the groundwater are listed below:
Contaminant MCLfug/11 MCLG fua/11
Trichloroethene 5 0
1,1,1-Trichloroethane 200 200
1,l-Dichloroethene 7^ 7
1,1-Dichloroethane 81* -
1,1,2-Trichloroethane 53
cis-1,2 Dichloroethene 70 70
1,2-Dichloropropane 5 0
Tetrachloroethene 5 0
Vinyl Chloride 2 0
Toluene 1,000 1,000
Chloroform (THM) 100 0
Arsenic 50^
Manganese 80*
.*
Non-carcinogenic health-based concentration
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l.b.14. Discharge to either West Valley Creek, or the on
site pond shall comply with the appropriate substantive
requirements of the NPDES discharge regulations set forth in
the Pennsylvania NPDES Regulations 25 Pa. Code §92.31, and
the Pennsylvania Water Quality Standards (25 Pa. Code
§§93.1-93.9). Pursuant to the PADEP's determination
monitoring for all the other contaminants of concern shall
take place.
l.b.15. Discharge to the POTW will comply with the Clean
Water Act (33 U.S.C. §§1251 et sea.) pretreatment
regulations for existing and new sources of pollution as set
forth at 40 CFR Part 403. However, RI water quality data
indicates that pretreatment will not be warranted.
l.b.16. Air emissions from the air stripping units shall
meet the requirements of the Resource, Conservation &
Recovery Act ("RCRA") regulations set forth at 40 C.F.R.
Part 264, Subpart AA - (Air Emission Standards for Process
Vents). The total organic emissions from all affected
process vents at the Site are required to be below 1.4 kg/hr
and 2800 kg/yr under this regulation. Any vinyl chloride
air emissions from the groundwater treatment units will
comply with Section 112 of the Clean Air Act, 42 U.S.C.
§7412, National Emission Standard For Hazardous Air
Pollutants (NESHAPs). The relevant and appropriate NESHAP
for vinyl chloride is set forth at 40 C.F.R. Part 61,
Subpart F. The air emissions will also comply with the
Commonwealth of Pennsylvania regulations set forth at 25 Pa.
Code, Chapter 127, Subchapter A. Those regulations require
that emissions be reduced-to the minimum obtainable levels
through the use of Best Available Technology ("BAT"), as
defined in 25 Pa. Code §121.1.
l.b.17. The off site shipment of spent vapor phase carbon
units will comply with the requirements of: 25 Pa. Code
Chapter 262 Subparts A (relating to hazardous waste
determination and identification numbers), B (relating to
manifesting requirements for off-site shipments of spent
carbon or other hazardous wastes), and C (relating to
pretransport requirements; 25 Pa. Code Chapter 263 (relating
to transporters of hazardous wastes); and with respect to
the operations at the Site generally, with the substantive
requirements of 25 Pa. Code Chapter 264, Subparts B-D, I (in
the event that hazardous waste generated as part of the
remedy is managed in containers), 25 Pa. Code Chapter 264,
Subpart J (in the event that hazardous waste is managed,
treated or stored in tanks). 40 C.F.R. 268 Subpart C,
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Section 268.30 and Subpart E (regarding prohibitions on land
disposal and prohibitions on storage of hazardous waste).
i.e. Groundwater Remedy Implementation
It may become apparent during implementation or operation of the
ground water extraction system and its modifications, that
contaminant levels have ceased to decline and are remaining
constant at levels higher than Performance Standards over some
portion of the contaminant plume. If EPA, in consultation with
the PADEP, determines that implementation of the selected remedy
demonstrates, in corroboration with hydrogeological and chemical
evidence, that it will be technically impracticable to achieve
and maintain the Performance Standards throughout the entire area
of the contaminant plume, EPA, in consultation with the
Commonwealth, may require that any or all of the following
measures be taken, for an indefinite period of time, as further
modification(s) of the existing system:
a) long-term gradient control provided by low level pumping, as
a containment measure;
b) chemical-specific ARARs may be waived for'those portions of
the aquifer that EPA, in consultation with the Commonwealth
determine that are technically impracticable to achieve further
contaminant reduction such determinations shall be reevaluated at
each subsequent five-year review;
c) institutional controls may be provided/maintained to restrict
access to those portions of the aquifer where contaminants remain
above performance standards; and
d) remedial technologies for ground water restoration may be
reevaluated.
The decision to invoke any or all of these measures may be made
during implementation or operation of the remedy or during the 5-
year reviews of the remedial action. If such a decision is made,
EPA shall amend the ROD or issue an Explanation of Significant
Differences.
l.d. Estimated Costs
Estimated Capital Costs: $2,380,000
Estimated Total O&M Costs: $5,153,500
Estimated 30 Year Total Present Worth Costs: $7,533,500
A detailed cost estimate of this portion of the Selected
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Remedy can be found in Appendix D. The estimate is titled
Groundvater Alternative 4Afl) and 4&(l).
2. Excavation and Off-Site Disposal of Contaminated Soils
2.a. Description
This portion.of the remedy consists of excavation and
offsite disposal of an estimated 232 cubic yards of soil
contaminated with VOCs including TCE and 1,1,1 TCA from the
AIW Frank Corporation's former above ground solvent storage
tank area.
2.b. Performance standards
2.b.l. As part of the remedial design additional sub-
surface soil samples shall be collected in the above ground
solvent storage tank area, and analyzed to fully
characterize the areal extent of the subsurface soil
contamination and assess the need for additional excavation.
Figure 2 illustrates the general location of this area.
This area was not fully characterized in the Remedial
Investigation. The number and location of the subsurface
soil samples, and the analytical parameters and methods to
be used will be determined by EPA, in consultation with the
PADEP, during the remedial design phase.
2.b.2. All soils with concentrations of contaminants of
concern that are above levels protective of groundwater from
the AIW Frank former above ground solvent storage tank area
shall be removed. Excavation will continue until the soil
left in place meets the soil clean-up standards. The
listing of the subsurface soil contaminants of concern at
the Site and the appropriate soil clean-up standards are:
Contaminant Soil Clean-up Standard fucr/1)
Trichloroethene 2000
1,1 dichloroethene 1000
1,1 dichlorethane 500
1,1,1 trichloroethane 1000
tetrachloroethene 2000
These levels are based on an amount of residual
contamination that if left in the soil, would not cause the
ground water to be contaminated above Maximum Contaminant
Levels. These levels, if left in the surface and subsurface
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soils would also not pose a carcinogenic risk greater than
EPA's risk range of 1 x 10'4 to 1 x 10"6 for ingestion and
dermal contact exposure routes.
2.b.3. Any asphalt and subbase in the excavation area will
be removed and staged for offsite disposal in accordance
with applicable laws and regulations. Asphalt and subbase
debris may be eligible for disposal as non hazardous under
the land disposal restrictions "debris rule" 40 C.F.R. §
268.45 following the appropriate determinations.
2.b.4. Excavation will then begin in the AIW Frank former
above ground solvent storage tank area using a backhoe, and
the sides of the excavation area shall be cut back to a
minimum 2 to 1 slope to prevent side wall failure.
Structural stability shall be maintained with temporary
shoring or engineering measures as appropriate.
2.b.5. Sediment and erosion controls and temporary covers
will be installed to protect exposed soil from the effects
of weather consistent with PADEP's Bureau of Soil and Water
Conservation Erosion and Sediment Pollution Control Manual.
Erosion potential shall be minimized. Further, controls in
the form of Site grading to improve land grades, cover
soils, vegetation, and drainage channels to reduce erosion
potential from surface runoff may be required to minimize
erosion. Contaminated soils shall be prevented from being
washed into on site surface water and adjacent
uncontaminated and uncontrolled wetland areas during
remedial action implementation. The extent of erosion
control necessary will be determined by EPA, in consultation
with the PADEP, during the remedial design phase.
2.b.6. Excavation will continue to a depth of 8 feet or
shallower if bedrock is encountered.
2.b.7. Post-excavation sampling will be performed after the
excavation is completed pursuant to 2.b.6. above. Post-
excavation samples will be obtained from the base and the
sidewalls of the excavation to ensure that contamination is
not present above the soil clean-up Performance Standards
specified in 2.b.2. The location of the post-excavation
samples will be selected based on visual observation of
lithology and screening for VOCs using an appropriate
organic vapor detector. The samples will be analyzed for
VOCs on a quick turnaround basis using a method approved by
EPA.
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2.b.8. If the post-excavation sample concentrations are
below the clean-up level, the excavation will be backfilled
using clean soil. Clean borrow material will be brought in
to restore the excavation to original grade. Backfilling
will be performed, and the material will be compacted to
minimize the potential for subsidence. The excavation area
shall be covered with a layer of cover soil and revegetated
with native plant material until a viable cover is
established.
2.b.9. If VOCs are detected at levels above soil clean up
performance standards in the post-excavation samples,
additional material will be removed from the excavation area
and new samples obtained for analysis as discussed in 2.b.7.
Excavation and sampling activities will continue until the
results indicate that the soils do not contain contaminants
of concern above the performance standards. The excavation
area will then be restored as described in 2.b.8.
2.b.lO. Soil contaminated above the Performance Standards
specified in 2.b.2 above will be transported for disposal at
a permitted RCRA Subtitle C Hazardous Waste Landfill in
accordance with applicable laws and regulations. The
appropriate determinations will be made prior to disposal to
determine if further treatment is necessary prior to
disposal under RCRA land disposal restrictions.
2.c. Estimated Costs
Estimated Capital Costs: $ 513,000
Estimated Total O&H Costs: $ 0
Estimated 30 Year Total Present Worth Costs: $ 513,000
A detailed cost estimate of this portion of the Selected
Remedy can be found in Appendix D. The estimate is titled
Soil Remediation Alternative 4A.
3. Installation of a Water Line
3.a. Description
This portion of the remedy will provide a source of potable
water to the affected and potentially affected residents and
businesses by extending a municipal water line to the area
of concern in the vicinity of the Site (see Figure 12). The
Philadelphia Suburban Water Company currently supplies water
to West Whiteland Township, and has sufficient capacity at
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this time to provide water. Only those residents and
businesses currently impacted or potentially impacted by the
contamination in the groundwater will be connected to the
municipal 'water system.
3.b. Performance standards
3.b.l. The water supply system shall be constructed in
compliance with the requirements of the Philadelphia
Suburban Water Company and local and State requirements,
appropriate and authorized under CERCLA.
3.b.2. Connections shall be offered and provided to the
residences and businesses determined by EPA in consultation
with PAOEP during the remedial design to be affected or
potentially affected by the plume of contamination.
Potentially affected wells include those that are within or
near the boundaries of the contaminated groundwater plume
and those that are hydraulically impacted by the remedial
action.
3.b.3. The water line will be installed in a trench below
the freeze line and brought into the area of the
contaminated ground water plume so that all businesses and
residents that EPA determines are affected and potentially
affected by the ground water contaminant plume can be
provided hook ups.
3.b.4. Independent connections will then be brought from
the main into each of the businesses and residents affected
and potentially affected by the contaminated ground water
plume.
3.b.5. Following hook up, costs of public water usage shall
be the responsibility of the appropriate residence or
business.
3.b.6. Fire hydrants will be installed according to
Township requirements along the water line.
3.b.7. All areas impacted by the construction activities
during remedy implementation shall be graded, restored and
revegetated, as necessary.
3.b.8. The existing residential wells shall be abandoned
unless selected by EPA for long term monitoring, in
accordance with the requirements of the Pennsylvania Safe
Drinking Water Act 25 PA Code 109.602(c) and consistent with
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PADEP's Public Water Supply Manual, Part II, Section
3.3.5.11. and Chester County Health Department Rules and
Regulations Chapter 500.
3.b.9. The installation of the water line shall avoid,
minimize and mitigate impacts on floodplains and wetlands
(e.g., installation of the municipal water line). The
performance standard will be compliance with Executive Order
No. 11988 and 40 CFR Part 6, Appendix A (regarding
avoidance, minimization and mitigation of impacts on
floodplains), and Executive Order No. 11990 and 40 CFR Part
6, Appendix A (regarding avoidance, minimization and
mitigation of impacts on.wetlands).
3.c. Estimated Costs
Estimated Capital Costs: $ 2,529,000
Estimated Total O&M Costs: $ 0
Estimated 30 Year Total Present Worth Costs: $ 2,529,000
This cost estimate was broken out of the detailed
alternative costs for Alternative 3 Limited Actions and
Connection to Public Water Supply which can be found in
Appendix D. All costs for limited actions were subtracted
to arrive at the estimated costs presented above.
4. Removal, Decontamination and Off-site Disposal of Drums
and Sump.
4.a. Description
This component of the remedy will include the removal, and
off site disposal of four 55-gallon drums located in the AIW
Frank Corporation's rear building. The second portion of
this component of the selected remedy will be the removal of
a contaminated sump through excavation and off-site
treatment and disposal of the sump contents. The concrete
sump is located approximately 50 feet from the east property
line and 50 feet from the southeast corner of the rear
building foundation. The sump is approximately three feet
by three feet with a depth of two feet.
4.b. Performance standards
4.b.l. The drums and their contents will be treated and/or
disposed of following sampling and analysis for waste
characterization in accordance with 40 C.F.R. § 261.24 by
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the Toxic characteristic Leaching Procedure ("TCLP") at an
appropriate permitted RCRA landfill or other permitted
disposal or treatment facility.
4.b.2. The sump contents will be sampled and analyzed for
waste characterization prior to treatment and disposal off-
site in accordance with 40 C.F.R. § 261.24 by the Toxic
Characteristic Leaching Procedure ("TCLP11) at the
appropriate RCRA permitted treatment and/or disposal
facility. The sump may be eligible for disposal as non
hazardous under the land disposal restrictions "debris rule"
40 C.F.R. § 268.45 following the appropriate determinations.
4.b.3. If the drums and sump contents are determined to be
hazardous wastes the remedy shall be implemented consistent
with the following requirements, which are applicable, of PA
Code §§ 262.11 and 262.12 (relating to hazardous waste
determination and identification numbers), 25 PA Code
262.20-262.23 (relating to manifesting requirements for
offsite shipments of spent carbon or other hazardous
wastes), and 25 PA Code §§ 262.30 - 262.34 (relating to
pretransport requirements); 25 PA Code §§ 263.10 - 263.31
(relating to transporters of hazardous wastes); and with
respect to the operations at the Site generally, with the
requirements of PA Code §§ 264.10 - 264.56 and 264.170 -
264.178 (in the event that hazardous waste generated as part
of the remedy is managed in containers), 25 PA Code §§
264.190 - 264.199 (in the event that hazardous waste is
managed, treated, or stored in tanks); and if prohibited by
land disposal restrictions, 40 CFR Part 268 Subparts A and
C.
4.c. Estimated Costs
Estimated Capital Costs: $ 57,816
Estimated Total O&M Costs: $ 0
Estimated 30 Year Total Present Worth Costs: $ 57,816
This cost estimate was broken out of the detailed
alternative costs for Alternative 2 Limited Actions which
can be found in Appendix D. A detailed breakdown of the
above estimate can also be found in Appendix D entitled Drum
and Sump Removal Detailed Cost Estimate.
5. Structure Demolition or Restoration to code to allow
unrestricted site access.
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5. a. Description
The AIW Frank Corporation rear building, which is a one
story concrete/corrugated structure measuring 180 feet by
160 feet, has been specifically cited as an unsafe structure
by the West Whiteland Township building code officer. The
rear building, and any other on site structure which poses a
safety risk to on site workers when carrying out the remedy
or interferes with implementation of the selected remedy
called for in this ROD, will be demolished or restored to
code in accordance with all appropriate federal, state and
local regulations.
S.b. Performance Standards
S.b.l. The structure demolition or restoration to code will
include all Site structures which pose a safety hazard to on
site workers, or interferes with the implementation of the
selected remedy.
S.b.2. Any restoration of existing Site structures shall
comply with all Local codes.
S.b.3. Demolition debris waste will be disposed of at a
permitted construction/demolition waste landfill as defined
in 25 Pa Code Chapter 271.
5.c. Estimated Costs
Estimated Capital Costs: $ 250,000
Estimated Total O&M Costs: $ 0
Estimated 30 Year Total Present Worth Costs: $ 250,000
6. Institutional Controls to limit options for future Site
use.
6. a. Description
Institutional controls will be used to identify the Site as
property underlain by contaminated groundwater, and prevent
the use of contaminated ground water until the remedy is
completed.
6.b. Performance Standards
6.b.l. Until the Selected Remedy is completed, no newly
commenced or expanded ground water pumping in the aquifer
shall adversely affect the Performance Standards of
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hydraulic containment, prevention of plume migration and
capture of contaminants as specified above.
6.b.2. Drinking water supply wells shall not be installed in
the area of the contaminated ground water plume until the
remedy is completed and the Performance Standards for ground
water remediation are attained as specified in l.b.12.
above.
6.b.3. Deed restrictions shall be used to implement the
requirements of 6.b.l. and 6.b.2., along with other
appropriate means of achieving these requirements.
6.b.4. The deed restrictions will be appropriately recorded
with the Chester County Recorder of Deeds.
6.c. Estimated costs
Estimated Capital Costs: $ 11,000
Estimated Total O&M Costs: $ 0
Estimated 30 Year Total Present Worth Costs: $ 11,000
This cost estimate was broken out of the detailed
alternative costs for Alternative 2 Limited Actions which
can be found in Appendix D.
7. Additional Ecological Assessment
7.a. Description
The potential presence of a state-listed endangered species
was identified in the ecological assessment conducted for
the RI. A limited additional ecological assessment is
needed to determine the actual presence of the state-listed
endangered species in the Site area. The on site drainage
ditch and the area north of the rear building were not fully
characterized for their impact on ecological receptors in
the Remedial Investigation. Sampling will be conducted to
fully characterize the soils and sediment and assess the
need for additional excavation or grading in the ditch.
7.b. Performance Standards
7.b.l. A qualified herpetologist will be retained to
determine the presence of the endangered species. If
present, EPA will consult with the U.S. Fish & Wildlife
Service regarding potentially adverse impacts of remedial
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measures on the endangered species and or its habitat. If
it is determined to be necessary the remedy will be modified
as appropriate to avoid adverse impacts on the endangered
species or its habitat.
7.b.2. Surficial soil samples as well as sediment samples
shall be collected in the on site drainage ditch, north of
the rear building areas, and from pond sediments where the
ditch flow enters. The analytical parameters for sample
analysis will include, but may not be limited to, PCBs,
PAHs, mercury, copper, lead and zinc. The number and
location of the soil and sediment samples, and the exact
analytical parameters and methods to be used will be
determined by EPA, in consultation with the Commonwealth of
Pennsylvania, during the remedial design phase.
7.b.3. The additional ecological assessment will include
analysis of fish from the on site pond. The exact number,
method and analytical parameters of the sampling will be
determined by EPA in consultation with the Commonwealth of
Pennsylvania during remedial design.
7.b.4. If it is determined by EPA, in consultation with the
Commonwealth of Pennsylvania, that an unacceptable risk is
posed to ecological receptors due to surface water runoff
and/or treated effluent discharge to the on site pond via
the on site drainage ditch, excavation, grading and
revegetation, using the appropriate native vegetation, of
the drainage ditch soils will be conducted. Excavation,
grading and revegetation, if necessary, will be conducted
prior to any treated water discharge to the on site pond if
the pond discharge option is implemented.
7.c. Estimated Costs
Estimated Capital Costs: $ 48,240
Estimated Total O&M Costs: $ 0
Estimated 30 Year Total Present Worth Costs: $ 48,240
A detailed breakdown of the above estimate can also be found
in Appendix D entitled Additional Ecological Assessment
Detailed Cost Estimate.
8. Provision of Point of Use Carbon Filtration Units
8.a. Description
This portion of the remedy will require the provision and
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maintenance of point of use carbon filtration units to those
affected residents and businesses whose wells have been
found to have contaminants of concern above Maximum
Contaminant Levels.
8.b. Performance Standards
S.b.l. Point of use carbon filtration units shall be
installed for any residence or business whose well has been
found to have contaminants of concern above MCLs. The
point of use carbon filtration units shall be maintained to
insure that contaminants of concern are removed in
conformance with requirements of the SDWA, until such time
as the waterline extension has been implemented at which
time the units will be removed.
8.b.2. The carbon filtration units will be sampled bi-
annually for volatile organic contaminants using EPA method
524.1, or an equivalent method to ensure that breakthrough
of contaminants has not occurred.
8.b.3. If the bi-annual sampling indicates that
breakthrough has occurred the spent carbon unit will be
replaced and the spent carbon will be sent for regeneration,
or disposal in compliance with all State and Federal
regulations.
8.c. Estimated costs
Estimated Capital Costs: $ 6,000
Estimated Total O&M Costs: $ 13,500
Estimated 30 Year Total Present Worth Costs: $19,500
A detailed breakdown of the above estimate can also be found
in Appendix D entitled Provision of Carbon Filtration Units
Detailed Cost Estimate.
9. Performance of a Phase I archeological survey prior to any
intrusive remedial activities.
9. a. Description
This portion of the remedy calls for the performance of a
Phase I archeological survey prior to any intrusive remedial
activities.
9.b. Performance standards
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9.b.l. The Phase I archeological survey will be conducted
prior to any intrusive remedial activities and will be in
accordance to and compliance with the National Historic
Preservation Act of 1986 16 U.S.C. § 470 (Chapters 106 and
110(f) and 36 CFR part 800) and the Archeological and
Historic Preservation Act of 1974 (16 U.S.C. § 469a-l).
9.b.2. The remedy will be adjusted, as necessary, during
implementation of the remedy to comply with the substantive
requirements of the National Historic Preservation Act of
1986 16 U.S.C. S 470 (Chapters 106 and 110(f) and 36 CFR
part 800) and the Archeological and Historic Preservation
Act of 1974 (16 U.S.C. § 469a-l)..
9.c. Estimated costs
Estimated Capital Costs: $ 5,000
Estimated Total O&M Costs: $ 0
Estimated 30 Year Total Present Worth Costs: $ 5,000
10. Long Term Groundwater Monitoring
10.a. Description
This portion of the remedy calls for a long term sampling
plan to evaluate the effectiveness of the ground water
extraction and treatment system.
10.b. Performance Standards
lO.b.l. A long-term ground water monitoring program shall be
implemented to evaluate the effectiveness of the ground
water pumping and treatment system.
10.b.2. The plan for the long-term ground water monitoring
program shall be included in the operation and maintenance
plan for the ground water extraction and treatment system.
The plan shall include the sampling of a sufficient number
of wells to monitor the effectiveness of extraction and
treatment system. EPA, in consultation with PADEP, will
determine the number and location of monitoring wells
necessary to verify the performance of the remedial action.
10.b.3. The installation of additional monitoring wells may
be required. Numbers and locations of these monitoring
wells shall be determined by EPA during the remedial design,
in consultation with the PADEP.
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10.b.4. The wells shall be sampled quarterly for the first
three years. Based on the findings of the first three years
of sampling, the appropriate sampling frequency for
subsequent years will be determined by EPA in consultation
with the PADEP.
10.b.5. Sampling and operation and maintenance shall
continue until such time as EPA, in consultation with the
Commonwealth of Pennsylvania, determine that the performance
standard for each contaminant of concern has been achieved
to the extent technically practicable throughout the entire
area of ground water contamination.
lO.b.6. If EPA and the Commonwealth make such a
determination, the wells shall be sampled for twelve
consecutive quarters throughout the entire plume and if
contaminants remain at or below the performance standards,
the operation of the extraction system shall be shut down.
10.b.7. Annual monitoring of the ground water shall continue
for five years after the system is shutdown.
10.b.8. If subsequent to an extraction system shutdown,
annual monitoring shows that ground water concentrations of
any contaminant of concern are above the Performance
Standard set forth in l.b.12. above, the system shall be
restarted and continued until the performance standards have
once more been attained for twelve consecutive quarters.
Semi-annual monitoring shall continue until EPA determines,
in consultation with the Commonwealth of Pennsylvania, that
the Performance standards in l.b.12. for each contaminant of
concern has been achieved on a continuing basis.
10.c. Estimated Costs
The estimated costs for long term ground water monitoring
are included in the cost estimate for the ground water
extraction and treatment system listed in I.e. above.
Worker Safety
During all Site work, Occupational Safety and Health
Administration (MOSHAn) standards set forth at 29 C.F.R.
Parts 1910, 1926 and 1904 governing worker safety during
hazardous waste operations, shall be complied with.
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Five-Year Reviews
Five-year reviews shall be conducted after the remedy is
implemented to' assure that the remedy continues to protect human
health and the environment. A 5-Year Review Work Plan shall be
required and shall be approved by EPA in consultation with the
PADER.
X. STATUTORY DETERMINATIONS
EPA's primary responsibility at Superfund sites is to select
remedial actions that are protective of human health and the
environment. Section 121 of CERCLA also requires that the
selected remedial action comply with ARARs, be cost effective,
and utilize permanent treatment technologies to the maximum
extent practicable. The following sections discuss how the
selected remedy for the AIW Frank/Mid-County Mustang Site meets
these statutory requirements.
Based on the baseline Human Health Risk Assessment for the
Site, measures should be considered to reduce potential risk from
the following sources: (1) VOCs in the ground water, (2) VOCs in
on site surface and subsurface soils. These media and
contaminants were selected because potential health hazards for
some exposure scenarios exceeded the EPA target range of 1.0 x
lO'4 (or 1 in 10,000), and 1.0 x 10'6 (or 1 in 1,000,000) for
lifetime cancer risk or a non-cancer Hazard Index of one (1).
The results of the Ecological Risk Assessment show the potential
for risk to ecological receptors, however, additional
characterization is need before a final determination can be
made.
The extension of a public water supply called for in the
selected remedy will provide a permanent alternative water supply
to affected and potentially affected residences and businesses
which will prevent current human exposure to ground water
contaminants, however, it will provide only limited reduction in
human exposure to Site soils and will not actively reduce the
contaminants in the soil or ground water, or prevent migration of
contaminated ground water. The ground water pump and treat
system will reduce the contamination in the ground water.
The selected remedy protects human health and the
environment by reducing levels of contaminants in the ground
water to those levels required by ARARs through extraction and
treatment. The groundwater extraction and treatment system shall
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reduce the levels of contaminants of concern in the groundwater
to achieve MCLs as required by the Safe Drinking Water Act, 42
U.S.C. §§ 300(f) - 300(j), and 40 C.F.R. § 141.61. Discharge of
the treated water through any of the discharge point options will
not adversely affect human health or the environment, provided
that all Performance Standards and ARARs are met.
The excavation of soil on site will protect human health and
the environment by removing the contaminated soil, thereby
eliminating the potential for contaminant migration to the ground
water and preventing future exposure through ingestion,
inhalation and dermal contact.
Implementation of the selected remedy will not pose any
unacceptable short term risks or cross media impacts to the site,
or the community.
B. Compliance with and Attainment of Applicable or Relevant
and Appropriate Requirements ("ARARs")
The selected remedy will comply with all applicable or relevant
and appropriate chemical-specific, location-specific and action-
specific ARARs. Those ARARs are:
1. Chemical Specific ARARs
The selected remedy will be designed to achieve
compliance with chemical-specific ARARs related to ground
water at the site. The contaminants of concern from the AIW
Frank/Mid-County Mustang Site and their respective MCLs
which are listed under the performance standards of the
Ground Water Extraction and Treatment Section of the
Selected Remedy of this ROD, are applicable for this action.
The groundwater extraction and treatment system shall reduce
the levels of contaminants of concern in the groundwater to
achieve MCLs as required by the Safe Drinking Water Act, 42
U.S.C. §§ 300(f) - 300(j), and 40 C.F.R. § 141. If a non-
zero Maximum Contaminant Level Goal ("MCLG") has been
established and is more stringent than the MCL, the MCLG
shall be attained.
2. Location Specific ARARs
The Pennsylvania Erosion Control Regulations, 25 PA
Code §§ 102.1 - 102.5, 102.11 - 102.13, and 102.21 -102.24,
regulate erosion and sedimentation control. These
regulation are applicable to the grading and excavation
activities associated with the selected remedy.
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The National Historic Preservation Act of 1986/ 16
U.S.C. § 470 (Chapters 106 and 110(f), and 36 CFR part 800)
and the Archeological and Historic Preservation Act of 1974
(16 U.S.C. § 469a-l) are applicable to the performance Phase
I archeological survey. The selected remedy shall comply
with the applicable substantive requirements of theses
statutes.
No Federally listed endangered species are in the
vicinity of the Site. However, it was determined that there
was a possibility that some State listed/Federal candidate
endangered species may exist in the Site area. Therefore,
the Endangered Species Act, 16 U.S.C. 1531, will be
applicable if the State listed/Federal candidate endangered
species are present to provide for appropriate consultation
and prevent the taking of the protected species and the
destruction of habitat.
The Dam Safety and Waterway Management Act, 25 PA Code
§§ 105.1 - 105.3, 105.12, and 105.19 are location-specific
regulations for the drainage ditch as it^ is considered a
water of the Commonwealth.
40 C.F.R. § 6.302 Subpart C (a), (b) and (g) addressing
wetlands, floodplain, and fish and wildlife apply to the
ground water, drainage ditch and wetlands.
3. Action Specific ARARs
Section 402 of the Clean Water Act, 33 U.S.C. §1342,
and the National Pollutant Discharge Elimination System
("NPDES") discharge regulations set forth at 40 CFR §§
122.41-122.50, the Pennsylvania NPDES regulations (25 PA
Code §§ 92.1 and 92.31), the Pennsylvania Wastewater
Treatment Regulations (25 PA Code §§95.1 - 95.3), and the
Pennsylvania Water Quality Standards (25 PA Code §§93.1 -
93.9) are applicable. Ground water collected under the
selected remedy shall be treated to comply with these
applicable substantive requirements prior to discharge.
Any treated effluent discharge to the POTW will comply
with the federal Clean Water Act (33 U.S.C. §§ 1251 et seq.)
pretreatment regulations for existing and new sources of
pollution as set forth at 40 CFR Part 403.
VOC emissions from the air stripper tower will be
governed by the Pennsylvania Department Of Environmental
Protection air pollution regulations. Air Emissions will
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also comply with 40 C.F.R. §§ 264.1030 - 264.1034 (Air
Emissions Standards for Process Vents), and with 40 C.F.R.
§§ 264.1050 - 264.1063 (Air Emissions Standards for
Equipment Leaks). Air emissions of Vinyl Chloride will
comply with 40 C.F.R. Parts 61.60 - 61.69, National Emission
Standards for Hazardous Air Pollutants (NESHAPS).
Federal Clean Air Act requirements, 42 U.S.C. §§7401 et
seq.. are applicable and must be met for the discharge of
contaminants to the air. Air permitting and emissions ARARs
are outlined in 25 PA Code §§ 121.1 - 121.3, 121.7, 123.1,
123.2, 123.31, 123.41, 127.1, 127.11, 127.12, and 131.1 -
131.4-. 25 PA Code § 127.12 requires all new air emission
sources to achieve minimum attainable emissions using the
best available technology ("BAT"). In addition, the PADEP
air permitting guidelines for remediation projects require
all air stripping and vapor extraction units to include
emission control equipment.
Fugitive dust emissions generated during remedial
activities will be controlled in order to comply with
fugitive dust regulations in the federally-approved State
Implementation Plan ("SIP") for the Commonwealth of
Pennsylvania, 25 PA Code §§ 123.1 - 123.2. and the National
Ambient Air Quality Standards for Particulate Matter in 40
C.F.R. §§ 50.6 and PA Code §§ 131.2 and 131.3
25 PA Code §§ 123.31 and 123.41 which prohibits
malodors detectable beyond the AIW Frank/Mid-County Mustang
property line is applicable to the selected remedial
alternative.
25 PA Code §§ 264.90 - 264.100 (Subchapter F),
regarding groundwater monitoring is applicable to the
selected remedial alternative.
RCRA listed constituents (TCE, 1,1,1 TCA, etc.) will
exist in the excavated soil, therefore, the remedy will be
implemented consistent with the following substantive
requirements, which are applicable to on site activities, of
PA Code §§ 262.11 - 262.13 (relating to hazardous waste
determination and identification numbers), 25 PA Code §
262.34 (relating to pretransport requirements); 25 Pa. Code
Chapter 263 (relating to transporters of hazardous wastes);
and with respect to the operations at the Site generally,
with the substantive requirements of 25 Pa. Code Chapter
264, Subparts B-D, I (in the event that hazardous waste
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generated as part of the remedy is managed in containers);
and 40 C.F.R. §§ 268.1 - 268.7 and 268.40 (RCRA land
disposal restrictions).
25 Pa. Code Chapter 107 is applicable to the drilling
of any new wells at the Site. These regulations are
established pursuant to the Water Well Drillers License Act,
32 P.S.§ 645.1 et sea.
The substantive requirements of the PADEP's Public
Water Supply Manual, Part II, Section 3.3.5.11 and Chester
County Health Department Rules and Regulations Chapter 500,
regarding the proper plugging and abandonment of existing
pumping and monitoring wells are relevant and appropriate in
order to eliminate the possibility of these wells acting as
a conduit for future groundwater contamination.
The substantive requirements of the Delaware River
Basin Commission (18 CFR Part 430) are applicable. These
regulations establish requirements for the extraction and
discharge of ground water within the Delaware River Basin.
However, no modifications to the Selected Remedy are
expected due to the extraction and discharge called for in
the remedy.
4. To Be Considered ("TBC") .Standards
Pennsylvania's Ground Water Quality Protection
Strategy, dated February 1992 and EPA's Ground Water
Protection Strategy, dated July 1991 are TBCs.
OWSER Directive #9355.0-28, Control of Air Emissions
from Superfund Air Strippers at Superfund Ground Water
Sites, is a "to be considered" (TBC) requirement.
OWSER Directive #9355.7-04, Land Use in the CERCLA
Remediation Selection Process, is a "to be considered" (TBC)
requirement.
OWSER Directive #9234.2-25, Guidance for Evaluating the
Technical Impracticability of Groundwater Restoration, is a
"to be considered" (TBC) requirement.
The PADEP document entitled "Cleanup Standards for
Contaminated Soils", dated December 1993, is a TBC
requirement that establishes soil cleanup standards deemed
to be acceptable under the residual waste regulations.
-69-
-------
AIW Frank - ROD
Sediment and erosion controls and temporary covers will
be installed to protect exposed soil from the effects of
weather in accordance with PADEP, Bureau of Soil and Water
Conservation's Erosion and Sediment Pollution Control Manual
which is a "to be considered" (TBC) requirement.
Any on site landscaping will be in accordance with
Office of the Federal Executive; Guidance for Presidential
Memorandum on Environmentally and Economically Beneficial
Landscape Practices on Federal Landscaped Grounds, 60 Fed.
Reg. 40837 (August 10, 1995) which is a "to be considered"
(TBC) requirement.
C. Cost-Effectiveness
The selected remedy is cost-effective in providing overall
protection in proportion to cost, and meets all other
requirements of CERCLA. Section 300.430(f) (ii) (D) of the NCP
requires EPA to evaluate cost-effectiveness by comparing all the
alternatives which meet the threshold criteria - protection of
human health and the environment and compliance with ARARs -
against three additional balancing criteria: long-term
effectiveness and permanence; reduction of toxicity, mobility or
volume through treatment; and short-term effectiveness. The
selected remedy meets these criteria and provides for overall
effectiveness in proportion to its cost. The combined estimated
present worth cost for the selected remedy presented in this
Record of decision is $10,967,056. The proposed plan estimated
that the preferred alternative would costs $11,400,000. The
difference in estimated costs from the proposed plan to this
Record of Decision is primarily do to the proposed plan
estimating that 18 residents would require carbon filtration
units and the associated sampling, analysis and periodic
replacement of the carbon units, whereas, the selected remedy
estimates that at most 5 carbon units would be required. Also,
the proposed plan estimate mistakenly counted the costs of
installing and analyzing additional monitoring wells for
predesign studies and long term ground water monitoring, as well
as, the 30 yr sampling & analysis costs associated with long term
ground water monitoring. Detailed capital and O&M cost estimates
for the alternatives included in the selected remedy are shown in
Appendix D.
The treated ground water discharge options will each have
their own unique costs. At this time, depending on whether the
treatment system can attain the substantive requirements of the
NPDES permit requirements, discharge to the on site pond appears
to be the most cost effective option when compared to direct
-70-
-------
AJW Frank - ROD
discharge to West Valley Creek at the location described in the
proposed plan. This is a result of the decreased piping and
excavation required. However, discharge to the proposed West
Whiteland spray irrigation POTW would likely not require
pretreatment for Arsenic which could lower the cost of the
Selected Remedy by $500,000 (the estimated cost for
pretreatment). Because the spray irrigation POTW is in the
conceptual design phase EPA does not have sufficient information
to determine the exact costs of this discharge option, however.
As the specific costs for each option becomes available during
the remedial design they will be carefully evaluated and weighed
against the cost effectiveness of the other discharge options.
D. Utilization of Permanent Solutions and Alternative
Treatment Technologies to the Maximum Extent Practicable
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized while providing the best balance
among the other evaluation criteria. Of those alternatives
evaluated that are protective of human health and the environment
and meet ARARs, the selected remedy provides the best balance of
tradeoffs in terms of long-term and short-term effectiveness and
permanence, cost, implementability, reduction in toxicity,
mobility, or volume through treatment, State and community
acceptance, and preference for treatment as a principal element.
Under the selected remedy, groundwater extraction through
source and migration control wells and treatment of groundwater
using air stripping is more cost-effective than the other
alternatives evaluated. The selected remedy will reduce
contaminant levels in the Class IIA aquifer, a known source of
drinking water, and reduce the risks associated with ingestion
and inhalation of the groundwater to the maximum extent
practicable, as well as provide long-term effectiveness.
The selection of excavation and offsite disposal of
contaminated soils, provides the best balance of trade offs among
the nine NCP selection criteria. The remedy provides the highest
degree of long-term effectiveness and permanence, reduces
mobility and reduces risk to human health and the environment.
B. Preference for Treatment as a Principal Element
The selected remedy satisfies, in part, the statutory
preference for treatment as a principal element. The
contaminated groundwater alternative addresses the primary threat
of future ingestion and inhalation of contaminated groundwater
-71-
-------
AIW Frank - ROD
through treatment using air stripping.
ZI. DOCUMENTATION OF CHANGES FROM PROPOSED PLAN
A. Treated Ground Water Discharge options
The treated groundwater effluent will be discharged to either: 1)
West Valley Creek as described in the proposed plan, 2) the on-
site pond, or 3) the proposed West Whiteland spray irrigation
POTW, following predesign investigation of the treatment system
flow capacity, substantive NPDES requirements, or POTW
pretreatment requirements, and further determination of any
potential adverse effects of surface water runoff from the on
site drainage ditch and any dewatering of on site wetlands to
ecological receptors. The preferred alternative presented in the
June 16, 1995 proposed plan included discharge to West Valley
Creek. However, comments and concerns were raised during the
public comment period concerning this discharge point led EPA to
build more flexibility in the Selected Remedy concerning the
exact discharge location. The Selected Remedy does still include
a West Valley Creek discharge component, but it could be any one
(or a combination) of the three identified locations. A
selection as to which discharge option will be implemented will
be made by EPA in consultation with PADEP during the remedial
design. EPA will keep citizens informed of the final discharge
decision process through distribution of fact sheets and periodic
public meetings during the remedial design.
Treated effluent will be discharged through a new outfall, or
through a piping system if discharge is to the spray irrigation
POTW, that shall be constructed as part of the remedial action.
Discharge to West Valley Creek at the location just west of North
Ship Road as contemplated in the June 16, 1995 Proposed Plan has
been retained as a discharge option. A comprehensive analysis of
the groundwater extraction system will be made prior to
implementation to determine the thermal and flow effects the
system may have on West Valley Creek. West Valley Creek will be
monitored downstream of any discharge to ensure the requirements
for temperature and dissolved oxygen are maintained. Corrective
measures will be implemented if it is determined that the
temperature and dissolved oxygen content of the stream are
adversely affected. The establishment of background conditions
for West Valley Creek shall include, at a minimum, temperature,
dissolved oxygen and flow readings from downstream locations, the
exact number and locations to be determined during the remedial
design. The analysis shall include, if necessary, mitigation
-72-
-------
AIW Frank - ROD
plans for maintaining the background thermal regime of West
Valley Creek. The primary mitigation tool available would be the
return of treated effluent directly to the stream via direct
discharge if tHe effluent is within temperature requirements.
Discharge to the on site pond was selected as a discharge option
following comments received during the public comment period.
The'comments focused on avoidance of direct stream discharge and
preferences for discharge options which partially recharge the
aquifer in the vicinity of the site, if possible. Discharge to
the on site pond, if the substantive requirements of the NPDES
permit can be attained, would provide partial recharge of the
aquifer through the intermittent portion of West Valley Creek
west of the pond and the pond wetland area itself. The partial
aquifer recharge along with surface evaporation in the pond will
reduce the amount of actual discharge to the perennial portion of
West Valley Creek.
Discharge to the West Whiteland spray irrigation POTW was
selected as a discharge option following comments received during
the public comment period. However, at this time, the West
Whiteland POTW spray irrigation sewer treatment system is in the
conceptual design phase. EPA currently does not have sufficient
information regarding the spray irrigation discharge option, but
will continue to investigate and evaluate it during remedial
design. EPA will remain in contact with West Whiteland Township
officials and their contractors during the remedial design in
order to assess the viability of discharge to the West Whiteland
spray irrigation POTW system. EPA will select the actual
discharge location in consultation with PADEP, after careful
consideration of all identified community concerns and technical
factors. (See Responsiveness Summary, Appendix E)
B. Land Recycling and Environmental Remediation standards
Act (now referred to as Act 2)
The June 16, 1995 Proposed Plan discussed the Commonwealth of
Pennsylvania relevant and appropriate standards for ground water.
At the time of the proposed plan the relevant and appropriate
standards specified that all ground water containing hazardous
substances must be remediated to "background" quality pursuant to
25 PA code §§ 264.97 (i), (j), and 264.100(a)(9). However, when
the proposed plan was issued, Pennsylvania Senate Bill #1,
referred to as the Land Recycling and Environmental Remediation
Standards Act (now referred to as Act 2) was signed into law by
Governor Ridge on May 19, 1995 and became effective on July 18,
1995, which was during the comment period for the AIW Frank/Mid-
County Mustang Site Proposed Plan. EPA has had time to review
-73-
-------
AIW Frank-ROD
and evaluate the applicability of Act 2 to the selected remedy.
EPA does not consider the Land Recycling and Environmental
Remediation Standards Act to be an ARAR for the AIW Frank/Mid-
County Mustang Site at this time.
-74-
-------
Appendix A
FIGURES
-------
Rgure 1. Site Location Map
-------
5ARTH«* oR.*iN».<3§ orrrw \
UNDERGROUND DRAINAGE
«P« OUTFALL
UNDERGROUND STORAGE TANKS
Rgure 2. Site Layout Map
-------
SURFACE WATB* POND
** RAUWJAO (CONHAl)
SURFACE WATBt
\ CONTOUR IMC
- STTEBOUNOARY
CONTOUR MTCTVAL O __
SCALE MMLES
Surface Hydrology in the Vicinity of the AIW Frank/Mid-County Mustang Site
Figure 3.
-------
/
SW/SD-09-01
SW/SD-05-01
SD-11-01
SW/SD-04-01
SW/SD-02-01
LEQBO
• STAFF GAUGE
SURFACE WATER AND
SEMBrr SAMPLE
** RALROAD (CONRAL)
SURFACE WATBt
CONTOUR UNE
- STTEBOUWAHY
CONTOUR NT8WAL • 10 POT
SW/SD-01-01
SCALE N MILES
Surface Water and Sediment Sample Locations
Figure 4.
-------
Fracture-Trace Analysis
Figure 5.
-------
AWWANK/MO-COUNTY MUSTANG
SITE BOUNDARY
MOMTOAMO. fleSKMNTIAL.
V CCNTOOBLJ*
SCALE IN FEET
CONTOUR INTERVAL - 10 FEET
SCALE IN MILES
QROUNDWATm CONTOUR
Potentiometric Surface of the Intermediate Unit
Figure 6.
-------
MM FRANK/M>«OUNTY MUSTANG
8TTE BOUNDARY
RUM LOCATIONS () X-
DR-01-01 \ \
DR-02-01
DR-03-01
DR-04-01
/
LEGEND
— ••SniMINMKY
/ SURFACfWATW
TK • UMBUKXM) STOMASE TAMC MMPUES
flEMBVTSAH
UQUDSAMU
COMTOUK 1WTHTVAL
Locations of USTs, Drum Samples, Building Samples, and Sump Samples
Figure 7.
-------
FR003 \
FR004 \
FR005 *.
FR006 \
LEGBC
ASBESTOS SAtfU
-- OfUMAOEPKAieonCM
=t= RALftOAD (COMUL)
~t SURFACE WATER
3CAUM
COMTOUM HTBWAL
Asbestos Sampling Locations
Figure 8.
-------
SO-07-01\
SURFACE SOL SAIVIES
-—SHE BOUNDARY
RAUOAO (COWUL)
SURFACe WATER
cowrouRiie
SO SURFACE SOL
COKTWJI MTBIVAt
Surficial SoU Sample Locations
Figure 9.
-------
9SO-.
330-
Lfsao
0 SUBSURFACE SOL SAMPLES
— ••SffEBOIMMftY
'=£= RAUWAD (COWMO
*'. SURFACE WATBI
'. CONTCU1LME
S3-
Subsurface Sou Sample Locations
Figure 10.
-------
MW-1O9
MW-109B
UBSBC
M STAFF GAUGES
« MOMTORMGWaj.
** RAUOAOCCONRAL)
\ StAFACE WATBt
. \
\ CONTOUR LfC
--- STTEBOUeARY
CONTOUR KT1BVAL - 10
SCALE IN DALES
0.25
Monitoring Well Locations Sampled u iring RI
Figure 11.
-------
Residential, Municipal, and Commercial Well Sample Locations
Figure 12.
-------
Distribution of TCE Concentrations (/tg/L) in the Overburden/Shallow Water-
Bearing Zone. The distributions of TCE are very approximate due to limited
data.
Figure 13.
-------
Distribution of TCE Concentrations (pg/L) in Intermediate Water-Bearing Zone
Figure 14.
-------
MAfJ CHURCH \ H
FARM WELL
MW
' -. MW-1
MW-107
Distribution of TCE Concentrations Oig/L) in the Deep Water-Bearing Zone
Figure 15.
-------
LEGBO
JURSOCTIONAL WETLAND AREA
WETLAND REPLACEMENT BASMS
STAFF GAUGES
OnTKMO
HONnORMStMEU
— RA&flOMOICaNRAU
COMTOURU*
Q CONTDUBgffERVAL-IOFgET
SCALE IN MILES
Wetlands Location Map.
Figure 16.
-------
Appendix B
TABLES
-------
SUMMARY OF ORGANIC ANALYTICAL RESULTS - POTENTIAL
CONTAMINATION SOURCES (mg/L for liquids or mg/kg for solids)
Page 1 of 2
Analyle
Vlelhylene Chloride
Acetone
Carbon Disulfide
1 ,2-Dichloroeihane
I.l.l-Trichloroelhane
rrichlorofluoromethane
lenzene
t-Melhyl-2-pentanone
Z-Hexanone
Toluene
rhlorobenzene
iihylbenzene
Slyrene
Total Xylenes
3enzoic Acid
Naphthalene
2-Melhylnaphthalene
Tank Samples
TK4I
(Liquid)
Sampled
1/92
4964
TK-02
(Liquid
Sampled
1/92
15
5
27
41
179
730
1400
TK43
(Liquid)
Sampled
1/92
3J
20
.
25
112
400
1100
TK-04
(Liquid)
Sampled
1/93
I.S5J
0.605J
0.32J
19.5
I.25J
28
57D
70.SD
TK-04
(Solid)
Sampled
•
3.800D
3.600D
TK-05
(Liquid)
Sampled
1/93
O.I6J
0.27J
O.I6J
O.I2J
5.9
I.SD
1.60
Drum Samples
DR-01
(Solid)
Sampled
1/92
95
53
18
IJ
5
2J
2J
IJ
2J
DR-02
(Solid)
Sampled
1/92
38
2J
2J
8
DR-03
(Solid)
Sampled
1/92
7
IJ
20J
DR-04
(Solid)
Sampled
1/92
183
107
II
68
IJ
Building Samples
BD-OI
(Solid)
Samplec
1/92
5
IJ
BD42
(Solid)
Samplei
1/92
0.0138
0.0082
BD-03
(Solid)
Sampled
1/92
5
BD-04
(Solid)
Sampled
1/92 ~
6
5
8
18
2J
2J
21
Sump Samples
SMP
(Liquid)
Samplec
1/93 1
0.22
0.12
O.OI4J
0.02SJ
SMD
(Solid)
Sampled
1/93
4.8J
4.8J
(ft
H*
•Arithmetic average of inalyllcal rcsulli from TK-04 and ki duplicate sample.
J • Analytc present. Rqwned value may not be accurate or prccUe.
O • Analyle sample wit diluted.
L - Analyu picscm. Reported value may be biased tow. Actual value b expected to be higher.
Reference: Appendis C-2 and C-3 for daia luminary labta and laboratory rcporu.
-------
SUMMARY OF ORGANIC ANALYTICAL RESULTS - POTENTIAL
CONTAMINATION SOURCES (mg/L for liquids or mg/kg for solids)
Page 2 of 2
Analyle
Acenaphlhylene
taenaphihene
toihylphihalaie
:luorene
4-Nilrosodiphenylamine
tienMilhrene
Anthracene
)i-n-buryl phlhalaie
;luoranihene
\renc
iurylbenzyl phlhalaie
Chrysene
)is(2-eihylhexyl)
ihinalale
)i-n-ociyl phlhalaie
)enzo(a)pvrene
vlethoxychlor
Aroclor 1254
Tank Samples
TK-OI
(Liquid)
Samplec
1/92
9J
8J
U
2J
TK42
(Liquid)
Sample!
1/92
I50J
290
7001
IIOJ
31
20J
I40J
201
TK-03
(Liquid)
Sample*
1/92
1001
310
710
IIOJ
50J
220
1401
70J
501
TK-04'
(Liquid)
Samplec
1/93
0.26S1
TK-04
(Solid)
Samplec
1/93
81
2.5J
5.2J
I.IJ
I.3J
TK-05
(Liquid)
Samplec
1/92
0.0091
0.0071
0.0181
Drum Samples
DR-OI
(Solid)
Samplei
1/92
21
81
60
DR-02
(Solid)
Sampled
1/92
21
401
701
31
181
DR-03
(Solid)
Samplei
1/92
21
II
21
DR44
(Solid)
Sampled
1/92
4L
6L
IL
Buildin
BD-OI
(Solid)
Samplei
1/92
21
171
91
BD-02
(Solid)
Sampled
1/92
I.5J
1100
Samples
BD-03
(Solid)
Sampled
1192
BD44
(Solid)
Sampled
i/fe
41
11
60
31
Sump Samples
SMP
(Liquid)
Sampled
1/92
0.037
SMD
(Solid)
Sampled
1/92
3.41
2.21
38DJ
670D
I
I
'Ariihinetic average of analytical reiulti from TK-04 and iu duplicate iiinple TK-04-O
J • Analyle proem. Reported value may not be accurate or precise.
D - Analyle umple was diluted.
L • Analyle present. Reported value may be biased low. Actual value n cupccled to be higher.
Reference Appendii C-2 and C-3 for data wmmary tables and laboratory reports.
-------
SUMMARY OF POSITIVE ASBESTOS ANALYTICAL RESULTS
POTENTIAL CONTAMINATION SOURCES
(PERCENT)
Analyte
Amosite
Chiysotile
Crocidolite
Other
Total
Asbestos Samples (Percent)
FF015
0
Trace
0
0
Trace
FF016
0
Trace
0
0
Trace
FF017
0
2
0
0
2
FF018
0
1
0
0
1
FF019
0
1
0
0
1
FF013
0
2
0
0
2
Table 2.
-------
ORGANIC ANALYTICAL RESULTS FOR SURF1CIAL SOILS10 («g/kg)
Page I of 2 *
Compound
Chloroform
2-Methylphenol
2-Meihylnaphihalene
4-Nilrophenol
Dieihyl phlhalaie
Phenanlhrene
Di-n-butylphlhalate
Fluoranlhene
Pyrene
Buiylbenzyl phlhalaie
I.I.I -Trichloroeihane
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
B£nzo(k)fluoranthene
Benzo(a)pyrene
Indenod .2.3-cd)pyrene
Dibenz(a.h)anthracene
Benzo(ft.h,i)Dervlene
Bis(2-ethvlhexvl)phihenlate
Concentration (i*e/ke)
SO-01
55J
49J
3
SO-02
350
36J
-
SO-03
47J
40J
SO-04
3J
63J
SO-05
I50J
130J
SO 06
2J
47J
91J
SO-07
170J
62J
200J
I70J
87J
89J
ISOJ
ISOJ
67J
SO 08
IJ
S3J
43J
77J
SO-09
so-io
SO-II
I40J
160J
I40J
I50J
360J
360J
2IOJ
200J
SOJ
230J
SO- 12*
1.5J
400J
3901
6IOJ
290J
85J
263. SJ
395J
S60J
560J
SOJ
1900
SO- 15
2J
9SJ
230J
260J
I30J
1601
350J
3SOJ
160J
99J
IIOJ
SO- 16
68J
84J
48J
90J
I
A
W
SwflcW Mih «>
-------
ORGANIC ANALYTICAL RESULTS FOR SURFICIAL SOILS"' (ug/kg)
Page 2 of 2
Compound
alpha-BHC
beia-BHC
della-BHC
Aldrin
Heplachlor Epoxide
Endosulfan 1
Dieldrin
4.4'-DDE
Endrin
Endosulfao II
4. 4 '-ODD
Endosulfan Sulfale
4.4'-DDT
Endrin Kelone
Endrin Aldehyde
alpha-Chlordane
f>amma-Chlordane
Aroclor 1254
Aroclor 1260
Concentration (jie/ke)
SO -01
5.2L
0.23J
2.IJ
I.IJ
90L
SO-02
0.25J
I7J
SO-03
O.I7J
3.2J
1.2J
0.098J
0.42J
SO4M
O.IIJ
230
58J
SO-05
I.2J
0.24J
0.46J
5.9J
0.22J
970
SO-06
O.IIJ
0.096J
I.IJ
120
SO-07
0.1 9J
0.21
0.22J
0.94J
ISO
SO-08
0.34J
O.I7J
0.43J
0.25J
60
SO-09
0.20
I.OJ
I.9J
0.80J
0.43J
I.4J
0.22J
SO 10
O.I8J
0.52J
35J
SO- II
1.8J
120
30J
SO- 12*
0.0541
0.47J
3.85J
3.9J
2.0J
0.08J
340
SO- 15
2.6
4.4
0.24J
0.6IJ
0.60J
0.8IJ
0.28J
O.I6J
O.ISJ
0.089J
SO- 16
0.54J
0.56J
I.IJ
0.93J
0.49J
O.IIJ
t
n
n
I
SwfkUl will «e ttfini la dib tiudy u wUi wkUn Arte Inches of Ihe earn! urtoe.
Aoalyu pnicn. Reported «•)« my m tt MXurtK « pcctM.
Antlyit urapte MI dUu»J.
Anlyw ftata. ttfn*d nlue nuy be ttuei low. Aouil nlut b cipecicd n be W»ht».
Aiiihmtik ivaije of intlytlctl rtiulu ftom > unplc «nd kl lk«» umplt.
I •
0 •
L .
CRQL • CMiwI Requited Qumiuiloo Lwll.
Rcfeicact Afp ndii C-l ud C-J brdtu nuuuty ubkt ind bbanunf itaora.
-------
INORGANIC ANALYTICAL RESULTS FOR SURFICIAL SOILS*" (rag/kg)
Compound
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
. Concentration (mg/kg)
SO-OI
3.410
4.4
I9.IK
0.4
117,000
7.3
9.2
10.500
27.9L
65.400
249
61. 2J
513
292J
125
SO-02
718
2.1
6.IK
0.13
152,000
5.180
82,000
III
4.2J
423
II.4J
44.1
SO-03
1.310
3.0
8.IK
0.44
161.000
7.040
91.900
133
6.6J
772
56.01
46.0
S044
389
1.8
78.7K
5.5L
266.000
22.8
10.7
1.620
18.800
71. 8L
26.300
165
I.I
97.0J
82.3
707K
I45J
463
SO-05
9,880
11.3
107
I.I
32,100
30.5
10.5
19,800
I43L
15,300
693
4I.6J
1.340
I62J
1,610
SO-06
18,700
5.2
44.2K
1.5
10,500
23.5
13.0
40,700
27. IL
2.900
312
I8.6J
753
0.67L
65.5J
88.8
SOW
11.600
4.6
50.0K
1.7
39,700
24.6
14.1
30,300
36.5L
8,780
538
31.11
660
i
96.3J
146
SO-08
16.500
5.7
50.7K
1.0
7,260
25.6
12.3
30,200
25.4L
3.250
372
20.11
900
69.0J
71.3
SO-09
15.500
6.6
99.3K
526
27.5
II. 7L
I6.6J
24.600
41.9
1.680
I.I40L
0.06
14.3
546
I.7K
40.4L
58.2J
SO-IO
17,400
8.2
76.0K
2,270
23.3
I6.4L
33.31
34.300
44.5
2.660
654L
18.2
991
I.8K
46.3L
98.4J
SO- II
15.100
5.4
4I.5K
15.100
19.4
I3.8L
38.01
52,300
39.8
11.400
460L
23.2
1.320
2.6K
34.0L
I35J
SO-12*
9.050
3.8
90.8K
37,000
28.9
12.4L
3.475J
25.850
116
21,900
333L
0.06
40.8
1.875
0.68K
7I.5L
1.650J
SO- 15
19.200
5.6
97.5
1.760
27.0
9.0
2I.7J
23.700
44.3
3,090
370L
14.1
920
0.97
43.8
77.01
SO 16
16.800
7.6
97.6
1,710
29.6
10.3
19.3)
28.300
70.8
1.640
873L
0.80
17.0
1.080
1.3
49.5
I27K
'" Surficial will we defined In (bit iludy as will wilhin three inches of the ground tuifKc.
I • Analyte present. Reported value may ml be Kcuraie or prcciic.
D - Anilyle sample was diluted.
L • Aralyteprcunl. Reported value miy be biased tow. Actual value b expected to be higher.
K - Analyle present. Reported value may be biased high. Attuil value u eipocted to be lower.
• Arithmetic average of analytical tesulu from • simple and ki duplicate sample.
Blanks indicate analyles were not proem ID the sample at the CRQL.
CR.QL • Contract Required Quanlitation Limh
Reference Appendii C-2 and C-3 for data summary lablci and laboratory repons.
-------
ORGANIC ANALYTICAL RESULTS FOR SUBSURFACE SOIL
SAMPLES AND ASSOCIATED WASTES G*g/kg)
Page 1. of 2
Anaiyte
Trichloroethylene
1 , 1 ,2-TrichIoroethane
retrachloroethvlene
Benzene •
[Toluene
Ethvlbenzene
1 . 1 -Dichloroethvlene
1 . 1 -Dichloroethane
Chloroform
1.1.1 -Trichloroefhatje
Diethvl Dhthalate
pi-n-buvl ohthalate
Fluoranthene
Stvrene
Pyrene
Xvlcne
Burvlbenzvl Dhthalate
\ois(2-
ethvlhexvDDhthalate
aloha-BHC
1,2-Dichloroethane
Total 1,2-
Dichloroethane
Depth
SS-01
ye-
ii
u
31
16
3J
5 500
43J
V
38J
0.46J
SS-02
3.9.
3J
SS-03
3* 10'
3J
38
Test Pit
TP-01-01M
2.5-3.0*
2.000J
110000
3.600J
10.000J
TP-01-2'
8.0*
25J
2J
2J
105
168J
37J
43J
TP-01-00
0.5'
2J
42J
Subsurface
Waste
TP-01-B
3.0'
2.700J
4.900J
1.200J
150J
140.000J
3.300J
21.000J
l.OOOJ
160J
3 300000J
3.800J
740J
430J
180J
j - Anaiyte present. Reported value may not be accurate or precise.
D - Anaiyte sample was diluted.
L - Anaiyte present. Reported value may be biased low. Actual value is expected to be higher.
* Arithmetic average of analytical results from a sample and its duplicate sample.
Blanks indicate analytes were not present in the sample at the Contract Required Quantitation Limit
(CRQL).
Reference Appendix C-2 and C-3 for data summary tables and laboratory reports.
Table 5.
-------
ORGANIC ANALYTICAL RESULTS FOR SUBSURFACE SOIL
SAMPLES AND ASSOCIATED WASTES Otg/kg)
Page 2 of 2
Analyte -
xta-BHC
delta-BHC
ga m mfl-BHC (L.iTl<'af*C)
Total 1.2-Dichloroethane
1.2-Dichloroethane
Heotachlor
Heptachlor Eooxide
Dieldrin
Endrin
Endosulfan n
Endosulfan Sulfate
4.4'-DDT
gaTtm>4-Oi'or*'inT'^
Aroclor 1254
Subsurface Soils
Depth
SS-01
3' 5"
0 13J
0.1 U
0.41J
0 15J
SS-02
3.9.
SS-03
3' 10"
0.19J
0.12J
0.28J
Test Pits
TP-01-01-M
2.5-3.0'
0.42J
0.50J
0.063J
0.22J
3.2J
0.77J
TP-01-02*
8.0'
0.255J
020J
0.27J
0 155J
TP-01-00
0.5'
026J
21J
Subsurface
Waste
TP-01-B
3.0'
0 0035
180J
430J
0.021
0.0056
J - Analyte present. Reported value may not be accurate or .precise.
D - Analyte sample was diluted.
L - Analyte present. Reported value may be biased low. Actual value is expected to be higher.
"Arithmetic average of analytical results from a sample and its duplicate sample.
Blanks indicate analytes were not present in the sample at the Contract Required Quantitation Limit
(CRQL;
Referen
.eference Appendix C-2 and C-3 for data summary tables and laboratory reports.
Table 5. continued^
-------
INORGANIC ANALYTICAL RESULTS FOR SUBSURFACE SOD-
SAMPLES AND ASSOCIATED WASTES (mg/kg)
Analyte
Aluminum
Arsenic
Barium
Beryllium
-jrtnrhirn
Calcium
Chromium
Cobalt
Copper
Iron
Lead
vfagnesium
Manganese
Mercury
Nickel
tatassium
Selenium
Silver
Sodium
rhallhim
Vanadium
7|rtc
Subsurface Soils
Depth
SS-01
3' 61
11.300
5.4
12.9K
0.98
IJl
8.5
18.8
33.000
880
138
0.17
16JJ
400
1.1L
40.4J
35.1
SS-02
3.9.
11.700
6.8
15.1K
1.4
1.170
7.6
44.1
41.800
21. 4L
880
423
22.91
397
0.89L
55. U
53.5
SS-03
3'10'
26.600
10.1
74.1K
- 5.8
9.400
35.7
81.2
115.000
78JL
3.010
3.750
2521
518
3.7L
1.0
206J
380
Test Pits
TP-01-01-M
2.5-3.0'
1,330
2.0
8. IK
0.31
87.800
4.3
5.320
42.000
77.4
119J
430
286J
58.1
TP-01-02*
8.0'
8,310
3.7
15.4K
1.7
5,320
25.4
31.300
5,235
524
22.9J
1,279
0.59L
1291
33.0
TP-01-00
0.5'
787
22.
4.5K
OJO
157,000
5,220
90.000
109
3JJ
586
7.0J
47.0
Subsurface
Waste
TP-01-B
3.0'
4,040
11.0
41.3K
3.6L
3.5L
156.000
15.9
13.9
941
11.500
54.9L
65.500
169
43.6
571
824K
581
K - Analyie PIULAL Refined value may be based biffe. .Annul viiiie B rincticil GO be lower.
J * Amiytc pfescBL Reponed vxlu£ tuy oot be SCCBISBB or precise.
D - Amlyte uiofile was dihirrd
L - Aaalyie present. Reponed vahie nay be based tow. Aeaai value is expected to be higher.
Arithmetic avenge of analytical route from * sample and 'at duplicate sanple.
Blanks indicate analytes were not present in die sample at die Contract Required Qumnaiion li""* (CRQL).
Reference Appendix C-2 and C-3 for daa summary tables and laborauxy reports.
Table 6.
-------
MAXIMUM CONCENTRATIONS OF ORGANIC ANALYTICAL RESULTS
GROUNDWATER
(/•g/L)
Page! of 3
Analyie
Vinyl Chloride
rhloroelhane
rrichlorofluoromelhane
1,1-Dichloroethylene
Carbon Disulfide
Acetone
Melhylene Chloride
Trans- 1 ,2-Dichloroelhylene
1,1-Dichloroeihane
:is-l ,2-Dichloroelhylene
rhloroform
1,1.1-Trichloroemane
1,2-Dichloroelhane
TrJchloroelhylene
1 ,2-Dichloropropane
Toluene
1 , 1 ,2-TrichloroeUiane
Tetrachloroelhylene
Elhyl benzene
M&P-Xylene homers
Isopropylbenzene
N-Propylbenzene
1 ,3.5-Yrimelhylbenzene
rert-Bulylbenzene
1 ,2,4-Trimethylbenzene
Sec-Bulylbenzene
P-lsopropyllolucne
N-Bulylbenzene
CRQL/NQL
1/5
1/5
1/5
1/5
1/5
5/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
i/5
1/5
1/5
MW-1
1.0
7.1
d.oJ
O.IJ
0.3
MW-2
1.3
2.0
0.6
0.6
16.0
13.1
3.6
MW-3
0.4J
8.9J
30.0
1.3
0.5J
2.1
1.2
0.2
0.2;
0.2
1.8
0.2
2.9
MW-101
0.08
MW-103A
4.3
1.3
0.7J
8.4
13.3
0.6J
I.I
O.IJ
MW-103B
6.2
0.6J
0.6J
0.2J
11.0
5.9
0.6J
O.I
0.5
Refer to Appendices C-2 and C-3 for complete analytical data.
NQL = Nominal Quaniilation Limits
See Table 4.8 for explination of other qualifier symbols.
-------
1
(p
§
I
MAXIMUM CONCENTRATIONS OF ORGANIC ANALYTICAL RESULTS
GROUNDWATER
0«g/L)
Page 2 of 3
Analyte
Vinyl Chloride
Zlilorocthane
Trichloroiluoroineihane
1 . 1 -TJichloroelhylene
Carbon Disulfide
Acetone
tothylene Chloride
Trans- 1.2-
Dichloroelhylene
1 , 1 -Dichloroe thane
:is- ( ,2-Dichloroethy lene
Chloroform
1,1,1-Trichloroelhane
1.2-Dichloroethane
Trichloroelhylene
1 ,2-Dichloropropane
Toluene
1 , 1 ,2-Trichloroelhane
Telrachloroelhylene
Ethyl benzene
Vl&P-Xylene Isomers
3-Xylene
sopropylbenzene
N-rropylbenzene
1 ,3,5-Trimethylbenzene
Tert-But
».2,4-Tr
See-But)
^-Butyrt
ylbenzene
methylbenzene
Ibenzene
wnzene
CRDL/NQ
L
1/5
1/5
1/5
1/5
1/5
5/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
l/$
1/5
1/5
1/5
1/5
MW-104A
2.5
9.4
1.0
0.1
0.3)
MW-104B
2.1
4.3
0.61
0.4)
18.0
8.2
0.3)
0.2
MW-105A
0.8)
4.6
1.6 ,
16.7
24.7
10.5)
) <
MW-105B
3.0
0.5)
6.2
10.0
20.4
5.0
0.4)
0.2)
0.6)
0.2)
MW-106
98.5
28.2
0.4)
4.0)
0.3)
0.7)
706.d
1.7
30.4
0.2)
4.2
16.2
0.2
MW-107A
1.2
0.9)
9.6
3.8
0.3)
0.5
MM-
107B
1.2
8.1
0.5
5.4
0.2
4.3
5.5
9.3
0.8
0.09)
0.7
Refer to Appendices C-2 and C-3 for complete analytical data.
NQL » Nominal Quantitation Limits
See Table 4.8 for explaination of other qualifier symbols.
-------
MAXIMUM CONCENTRATIONS OF ORGANIC ANALYTICAL RESULTS
GROUNDWATER
Page 3 of 3
Analyte
Vinyl Chloride
Zhloroelhane
rrichlorofluoromeihane
1 , l-Dichloroethylene
Carbon Disulfide
Acetone
Vlelhylene Chloride
Trans- 1 ,2-Dichloroethylene
1 , 1 -Dichloroelhane
:is- 1 ,2-Dichloroelhyiene
Chloroform
1.1,1 -Trichloroelhane
1 ,2-Dichloroelhane
rrichloroelhylene
1 ,2-Dichloropropane
Toluene
1,1,2-TrichIoroeihane
Tefrachloroelhylene
Eihyl benzene
tf &P-Xylene Isomers
3-Xylene Isomers
Isopropylbenzene
N-Propylbenzene
1 ,3,5-Trimelhylbenzene
rert-Bucylbenzene
1 ,2,4-trimelhylbenzene
kc-Bulylbenzene
N-Buiylbenzene
CRDL/NQL
1/5
1/5
1/5
1/5
1/5
5/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
1/5
I/S
1/5 -
1/5
1/5
1/5
MW-I08A
22.3
1.3
6.1
1,900
I3.2J
10.3
780.0
10,400
2.2
500.0
27.0
6,850
12.5
1,400
15.7
67.6
27.4
43.5
24.0
I.I
1.6
2.6
0.4J
4.8
0.5J
1.1
MW-109A
0.4J
0.07J
MW-109B
0.4J
(
0.2J
MW-F1
1.6
0.1J
MW-F2
0.6JH
0.8J
0.5J
5.1
O.IJ
MW-P1
1.0
0.9
0.3J
t
1
Refer lo Appendices C-2 and C-3 for complete analytical data.
NQL = Nominal Quantitation Limits
See Table 4.8 for explanation of other qualifier symbols.
-------
MAXIMUM CONCENTRATION OF INORGANIC ANALYTICAL RESULTS
GROUNDWATER (FILTERED AND UNFILTERED) G*g/L)
Page 1 of 4
Aoalyte
Aluminum
Arsenic
Barium
[Beryllium
fOdoxDiuxn
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
SDver
Sodium
Vanadium
Zinc
MW-1
Ftherad
208L
UL
17.3L
UL
UL
66,600
L
UL
UL
UL
247L
2.4B
37,500
L
3.1L
UL
UL
637
UL
2.710B
2.9B
13.6B
UaOmd
275
15.4
77,500
20.0
3,380
44.500
32.3
515
2,420
MW-2
Cft^HH*
mMBCB
85 .58
45.6
30,900
112B
3..5B
1.700
2.7
4.800
27.100
48.0B
IMterad
13,300
292
7.6
9.3
117,00
15.1
15.7
67.5
51,200
132
69,800
2,930
66.9
7,100
25,500
45.0
2,600
MW-3
Kind
62.6B
37.1
63,400
2.4B
9.5B
240
5.1B
28,900
134
7.3B
2,840
11.100
19.1
50.0B
IMBantf
824
39.1
67.000
10.2
17.3-
8,980
31,400
251
9.0
2,720
9,670
105
42.7
MW-101A
fitKTtd
45.3B
t
195
0.94B
1.3B
33.700
5.0
78.4B
7.5B
42,100
55.33
8,290
98,700
87.3
UnfiUmd
17,200
328
9.9
36.400
36.0
58.7
99,600
38/0
51,900
2,210
0.20
68.8
13,600
95,600
53.2
634
MW-103A
Fthentf
21. 4B
46.3
51.400
5.9
43. IB
7.2B
24,600
12.7
3.6B
10,000
23,800
43.6B
Unfitand
7,430
121
1.7
108,000
18.1
10.6
26.4
53,900
86.7
58,700
1,520
51.3
11,600
23,000
3.1
480
* Arithmetic average of a sample and its duplicate sample.
Refer to Appendices C-2 and C-3 for complete analytical data.
See Table 4.8 for description of other qualifier symbols.
Blank space mean; analyte not detected at CRQL.
Table 8.
-------
MAXIMUM CONCENTRATION OF INORGANIC ANALYTICAL RESULTS
GROUNDWATER (FILTERED AND UNFILTERED) (|tg/L)
Page 2 of 4
Analyte
Aluminum
Arsenic
Barium
Beryllium
f^dni'UTi
Calcium
GuTOIIUUIQ
Cobalt
Copper
ron
Lead .
Magnesium
Manganese
Mercury
Nickel
Potassium
Silver
Sodium
Vanadium
Zinc
MW-103B
Ftlorad
18.2B
31.2
68,500
13.900
27.900
177
4,570
18.2000
1.080
Unfitend
264
33.2
71,100
5.2
29,900
242
4.0
8.0
4,670
17,100
4.0
4,140
MW-104A
Fthmd
18.2
77,200
14,300
50,500
12.7
3,040
25.600
00
Uofitand
1,500
25.6
239,000
4.6
11.2
894
152,000
252
3.640
22,400
7.7
88.3
MW-104B*
Futcnrt
14.55
72,150
14,750
51.250
77.65
3,000
41,050
00
Unffimd
322
80,400
3.6
52.300
128
2,855
34,650
4.35
38.3
MW-105A
(rum
33.3B
10.6
54,400
7,940
34,400
58.5
2,790
19,900
Unfttanrt
91.3
13.0
83,00
52,400
124
3,010
19,100
MW-105B
Fitend
43 .48
122
68,500
•
290
1.1
24,300
26,000
UaGlmnt
2,300
250
49,900
3.0
23.6
20,800
47.5
235,000
507
184
23,800
23,900
12.8
189
* Arithmetic average of a sample and its duplicate sample.
Refer to Appendices C-2 and C-3 for complete analytical data.
See Table 4.8 for description of other qualifier symbols. Blank space means analyte not detected at
Blank space means analyte not detected at CRQL.
Table 8. continued...
-------
MAXIMUM CONCENTRATION OF INORGANIC ANALYTICAL RESULTS
GROUNDWATER (FILTERED AND UNFILTERED) 0*g/L)
Page 3 of 4
Analyte
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
vfanganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
MW-106
Fd«ctf
28.0B
UL
20.4
79,800
48,800
27.2
2,510
14,700
uflRttrarf
469
26.1
468.QOO
7.4
5.0
8.120
300,000
271
2.640
14.700
6.8
141
MW-107A
FHuaa
27.6B
23. 1L
UL
UL
60.500L
8.8L
1.6B
16.26
36.6B
5.1B
31,2001
5.4L
UL
5.7B
4,270L
3.9L
UL
17.100L
UL
70.5B
Uofflcnd
957
26.1
93,100
13.2
4.0
8.0
8,930
49,700
245
6.9
4,530.
17,100
8.1
77.9
MW-107B*
Rtenri
2,232.5
L
2.5L
76.35L
2.2L
UL
276.000
L
218L
UL
16B
377L
4.2B
7.630L
144L
UL
UL
87.250J
5.15L
UL
43.300J
UL
118J
UnflJand
58,050
287.5
18.4
628,5000
268.25
82.35
238
217.000
85
182,500
4,985
193.5
94,700
43.550
166.5
729
MW-108a
Fd«d
41. 3B
18.4
57.400
--
1.6B
4.7B
68.4B
5.4B
38,300
130
3.3B
6,690
21.600
97. 1J
Unfflnd
267
5.5
20.2
69,900
11.3
13.5
15,900
21.0
46,900
225
8.3
7,780
21,400
3.2
81.4
MW-109A
Facnrt
57.0B
35.3
47,400
75.8B
4.6B
23,700
50.1
10.200
26,300
61.7B
lM9m«
149,000
531
18.4
727,000
164
124
454
361,000
155
472,000
7.920
167
18.300
26.600
315
1.640
• Arithmetic average of a sample and its duplicate sample.
Refer to Appendices C-2 and C-3 for complete analytical data.
See Table 4.8 for description of other qualifier symbols.
Blank space means analyte not detected at CRQL.
Table 8. continued...
-------
MAXIMUM CONCENTRATION OF INORGANIC ANALYTICAL RESULTS
GROUNDWATER (FILTERED AND UNFILTERED) G»g/L)
Page 4 of 4
Analyte
Aluminum
Arsenic
Barium
[Beryllium
[cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
SUver
Sodium
Vanadium
Zinc
MW-109B
Filttnd
46.0B
11.9
17,300
34.7B
3.6B
15,300
44.5
13,300
33.300
23.5B
Uofitanri
2080
27.3
16,000
8.4
15,000
103,000
429
13.800
33,200
7.5
79.4
MW-F1
Frimri
13.1
48,000
29.000
12.7
995
19,200
UBniwd
46,200
4,550
27,500
114
962
17,700
221
MW-F2
Fitan4
136B
17.0
2.4B
53,700
484
5.0B
31,300
10.4
1,190
UL
3. IB
18,900
31.5B
Uofitend
12.2
63,600
4.430
37,400
113
1,400
18.800.
4.3
32.4
MW-P1
Fihmtf
72.8
0.94B
84.400
3.380
7.7B
26,000
446
7.4
4,150
UL
24,300
159
Uofitan*
462
84.9
57,300
36,500
21,900
729
3.730
19.600
6.6
2.330
* Arithmetic average of a sample and its duplicate sample.
Refer to Appendices C-2 and C-3 for complete analytical data.
See Table 4.8 for description of other qualifier symbols.
Blank space means analyte not detected at CRQL.
Table 8. continued.
-------
SUMMARY OF ELEVATED CONTAMINATION CONCENTRATIONS IN MONITORING WELLS
IN EACH WATER-BEARING ZONE Gig/L)
Analyte
1.1.1 -Trichloroethane
rrichloraethylene
eis-1 .2-Dicnloroemvlene
1 . 1 -Dichioreethy tone
1 . 1 -Dichlomemue
OvertMidea/Shallow Wells (jig/L)
MW-1
7.1
0.61
NO
ND
ND
O.U
MW-2
16
13.1
0.61
2J
0.6
3.6
MW-3
2.1
1.2
0.5J
ND
1.3
ND
MW-103A
8.4
13.3
0.7J
4.3
1.3
I.I
MW-107A
9.6
3.8
ND
1.2
ND
0.3J
MW-109A
ND
0.4J
ND
ND
ND
ND
MW-109B
ND
0.4J
ND
ND
ND
ND
Range of Site
Background
(UK/L)
< 1.0-1 .6
-------
VOLATILE ORGANIC COMPOUNDS - RESIDENTIAL WELLS (/ig/L)
Analyle
Chloromelhane
l.l-Dichloroethylene
rarbon Disulfide
Acetone
:is-l ,2-Dichloroelhylene
Chloroform
1,1,1-Trichloroelhane
1,2-bichloroethane
rrichloroethylene
1,2-Dichloropropane
rhlorobenzene
1,4-Dichlorobenzene
Dibromodichloromelhane
Carbon Telrachloride
ienzene
HW-01
Sampled
1/93
0.8J
0.7J
HW-02
Sampled
1/93
0.9J
2
0.6
3
HW-03
Sampled
1/93
HW-04
Sampled
1/93
HW-05
Sampled
1/93
HW-06
Sampled
1/93
9
3
U
4l
57
HvV-o)
Sampled
1/93
2
I7J
5
0.7J
2
0.5J
1
H\V-08
Sampled
1/93
6.61
HW-00
Sampled
1/93
9
0.9J
HW-IO
Sampled
1/93
251
48
180
5J
HW-II
Sampled
1/93
0.8J
2
HW-12
Sampled
1/93
34J
56
190
7J
HW-13
Sampled
1/93
6J
3
14
28
g
sr
J - Analyle present. Reported value may not be accurate or precise.
D • Analyle sample was diluted. ,
L - Analyle present. Reported value may be biased low. Actual value is expected to be higher.
Reference: Appendices C-2 and C-3.
-------
February 1995 Residential Well
Sampling Results
(all results in ppb)
CONTAMINANT
trichloroethene
1,1,1 trichloroethane
cis-1,2 dichloroethene
trichloroflouromethane
1,1 dichloroethene
1,1 dichloroethane
1,2 dichloropropane
tetrachloroethene
HW-01
2.9
HW-OS
32
17
3.1
1.5
5.1
-
HW-10
150
31
3.5
14
3.8
6.9
4.3
HW-11
2.9
HW-13
32
13
2.7
1.4
blank = not detected
Table 11.
-------
SURFACE WATER ORGANICS (Mg/L)
Aoalyte
Methylene Chloride
CRQL
(ug/L)
2
1
i
i
i
i
i
i
SW-01
3
4
SW-02
sw-04
SW-05
(Backmnd)
WMB^BW^^M
SW-06
— ^-«WM.
SW-08
^— — .^-^
SW-09
«*^«^«MMB
•^•••H^M^H
SW-10
^•"T™""^™^^
7J
U
21
5J
39
0.9
2
J - Analyte present. Reported value may not be accurate or precise.
D - Analyte sample was diluted.
L - Analyte present. Reported value may be biased low. Actual value is expected to be higher.
'Arithmetic average of a sample and its duplicate
Blanks indicate that the analyte was not present at the CRQL of a pg/L
CRQL - Contract Required Qnantitation T-J™*
Reference: Appendix C-2 and C-3 for data summary sheets and laboratory reports.
Table 12.
-------
SURFACE WATER INORGANICS (Filtered) (pg/L)
Analyte
Aluminum
Barium
Calcium
Cobalt
Copper
Jron
pad
Magnesium
Manganese
{Nickel
Potassium
Sodium
Zinc
CRQL
(Mg/U
200
200
5,000
50
25
100
3
5,000
15
40
5,000
5,000
20
SW-01
33:7
63,800
14,200
960
16,600
SW-02*
31.8
30,600
121
10.650
29.6
2.000
23,250
SW-04
20.6
33.400
12.100
5.4
1.430
27,900
SW-05
(Background)
20.6
38,500
14,400
1,220
33,000
SW-06
(BKkrvoaA
277
24.3
40,000
14,700
1.250
33,400
SW-08
(BMkfnund)
33.7
59,100
9,560
19.3
11,700
SW-09
(Badvouad)
37.4
48,000
7.650
30.4
10.400
218
SW-10
41.1
83,400
29,000
1,310
34,500
J - Analyte present. Reported value may not be accurate or precise.
D - Aoalyte ample was diluted.
L - Analyte present. Reported value may be biased low. Actual value is expected to be higher.
Arithmetic avenge of a sample and its duplicate.
Blanks indiCiW *frv the aoalyte was IHTT pffftfni at *h* CRQL of a fis/l»
CRQI* • Contract Reouired Quantitstion Limit
Reference: Appendix C-2 and C-3 for daa summary sheet* and lab
ry rep
Table 13.
-------
ORGANIC ANALYTICAL RESULTS FOR SEDIMENT (jig/kg)
Page I of 2
Analyle
Phenanthrene
Anthracene
Carbazole
Fluoranthene
Pyrene
Benzo(a)anlbracene
Chrysene
Benzo(b)fluoranlhene
Benzo(k)fluoranlhene
Benzo(a)pyrene
Indenod ,2,3-cd)pyrene
Benzo(g,h,i)petylene
alpha-BHC
beta-BHC
delia-BHC
gamma-BHC (Lindane)
Heptachlor
Concentration (/ig/kg)
SD-OI
65J
230J
250J
330J
160J
0.2IJ
SD4)2
IOOJ
23J
2IOJ
290J
2001
230J
320J
120J
0.17J
SD-03
75J
I90J
2IOJ
IOOJ
IOOJ
180J
88J
0.3SJ
1.3J
SD-04*
I25J
320J
40SJ
200J
I75J
340J
ISOJ
O.I4J
0.54J
SD-05
I90J
370J
390J
ISOJ
160J
2IOJ
70J
130J
0.21J
SD-06
90 J
230J
280J
I60J
HOJ
310J
140J
l.OJ
SD-07
0.089J
l.OJ
SD-08
160J
380J
440J
480
230J
0.29J
0.13J
0.33J
0.60J
SD-09
3SOJ
55J
S4J
390J
300J
330J
160J
I30J
110J
120J
0.61J
SD-IO
82J
HOJ
80J
74J
97J
62J
0.10J
0.86J
SD-ll*
55J
55J
SO- 12
IOOJ
•
2SOJ
210J
I20J
I70J
IIOJ
I30J
90J
IOOJ
g
n
J - Analyle present. Reported value may not be accurate or precise.
D • Analyle sample was diluted.
L • Analyle present. Reported value may be biased low. Actual value is expected to be higher.
• Arithmetic avenge of analytical results from a sample and its duplicate sample.
Blanks indicate analyles were not present in die sample at the Contract Required Quamilaiion Limit (CRQL).
Reference Appendix C-2 and C-3 for data summary tables and laboratory reports.
-------
ORGANIC ANALYTICAL RESULTS FOR SEDIMENT (jig/kg)
Page 2 of 2
Analyle
Aldrin
Heptachlor Epoxide
Endosulfan 1
Dieldrin
4.4' DDE
Endrin .
Endosulfan II
4,4'-DDD
Endosulfan Sulfale
4,4'-DDT
Meihoxychlor
Endrin Kelone
Endrin Aldehyde
alpha-Chlordane
gamma-Chlordane
Concentration (jig/kg)
SD-OI
0.067J
0.074J
0.098J
0.12J
0.2 IJ
0.29J
0.14J
O.IOJ
0.34J
SD-02
0.26J
0.29J
0.22J
4.0J
0.63J
I.3J
0.094J
0.15J
SD-03
0.21J
0.3SJ
O.I7J
2.2J
0.52J
0.38J
0.76)
0.34J
0.47J
0.19J
SD-Q4
0.24J
0.26J
O.I8J
0.52J
3.5J
O.SIJ
0.24J
0.76J
0.62J
0.71J
I.04J
0.23J
O.I6J
SD-05
O.I8J
O.I6J
1.6J
0.23J
O.I8J
O.^U
0.18J
2.0J
6.IJ
0.74J
0.25J
SD^>6
0.32J
0.097J
0.048J
0.030J
I.1J
0.36J
0.077J
0.70J
0.30J
0.22J
0.26J
0.074J
0.081
O.IOJ
SD-07
0.28J
O.I6J
0.68J
7.5J
0.16J
2.7J
0.74J
2.0J
0.37J
0.72J
2.IJ
2.8J
SD-08
0.62J
0.12J
3.2J
2.7J
0.20J
0.98J
7;4J
0.57J
2.5J
0.74J
O.SSJ
SD-09
O.I2J
0.07 IJ
0.1 U
0.23J
0.24J
0.26J
0.3SJ
0.075J
SD-IO
0.2SJ
0.16J
0.71J
0.20J
0.66J
O.S2J
0.2IJ
SD-ll*
SD-12
1
n
I
I
P-
I - Analyle present. Reported value may not be accurate or precise.
D - Analyle sample was diluted.
L - Analyle present. Reported value may be biased low. Actual value is expected to be higher.
* Arithmetic avenge of analytical results from a sample and its duplicate sample.
Blanks indicate analyles were not present in the sample at the Contract Required Qutatiudon Limit (CRQL).
Reference Appendix C-2 and C-3 for data summary tables and laboratory reports.
-------
INORGANIC ANALYTICAL RESULTS FOR SEDIMENT (mg/kg)
I
5"
H*
in
Analyle
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
Silver
Vanadium
Zinc
Concentration (mg/kg)
SD-OI
12.500
7.0
33.2K
0.80L
5,120
24.7
25.2K
32.7K
37,900
27.7
7.100
726
31. OK
2.6J
25.6K
162
SD-02
19,200
4.8
110
1.6
2,000
26.2
12.0
34.8
25,900
33. U
2,810
384
19.8
573
2.4L
35.9
106
SD-03
19.400
6.4
101
1.2
28,100
33.8
17.8
51.2
31.200
55.9
6,000
457
25.8
840
3.5L
39.8
164
SD^4*
20,000
4.9
122
1.4
22,200
36.0
15.9
47.6
28,700
60.0
5,200
287
24.3
968
39.1
165
SD-05
14.300
6.0
95.9K
2.IL
2,950
32.7
17.4K
38.0K
43.400
26.5
2,770
760
25.0K
526
5.8J
42.6K
196
SD-06
7,230
5.3
3I.6K
0.90L
1,760
24.7
I0.6K
26.4K
53,100
22.6
2.450
392
21.8K
2.6J
18.4K
124
SD-07
21.100
4.5
112
1.5
1,610
30.3
8.8
38.4
17.200
29.8
2,310
136
17.4
1,020
41.9
109
SD-08
8,710
6.8
46.2K
I.IL
2.940
21.0
20.9K
S5.6K
41,900
35.5
3,720
522
32.4K
266
4.2K
29.0K
175
SD-09
17,000
3.7
I18K
I.3L
7,220
22.8
17.6K
22.2K
29.600
23.2J
7,320
761
21.9K
363
4.5J
31.8K
100
SD-IO
4,320
2.8K
20.4
0.81
8,360
10.3
38.3
19,000
18.0J
5,840
172
15.5
3.3L
10.6
107
SD-11*
15,550
5.7
99.2
1.1
2,845
22.7
12.8
26.3
25,600
41.1
2.915
697
16.6
963
30.0
75.7
SD-12
18,500
7.2
114
1.2
2,920
22.5
12.7
24.2
27,200
40.8
2,930
728
17.0
1,080
0.6
35.0
78.9
K - Analyle present. Reported value may be biased high. Actual value is expected to be lower.
I • Analyle present. Reported value may not be accurate or precise.
D - Analyle sample was diluted.
L - Analyle present. Reported value may be biased low. Actual value is expected to be higher.
* Arithmetic average of analytical results from a sample and its duplicate sample.
Blanks indicate analyles were not present in the sample at the Contract Required Quanliiation Limit (CRQL).
Reference Appendix C-2 and C-3 for data summary tables and laboratory reports.
-------
SUMMARY OF RISK BY EXPOSURE ROUTE
AIW FRANK/MID-COUNTY MUSTANG SITE
CHESTER COUNTY, PENNSYLVANIA
1
n
Exposure Route
Groundwiter
Surface Water
Sediment
Surface Soil
Subsurface
SoU
Fish
Ingestion
Dermal
Inhalation
Total
Ingestion
Dermal
Tout
Ingeslbn
Dermal
Total
Ingestion
Dermal
Total
Ingestion
Dermal
Fugitive Dust
(Oral)
Fugitive Dust
(lob)
Total
Ingestion
Total
Adult Resident
Hazard
Index
3.5E+OI
7.30E-OI
2.0E-00
3.7E+OI
..
.-
--
..
--
•-
I.OE4I
2.9E-OI
3.9E4I
S.6E-02
2.4E40
I.IE4W
7E-II
2.5EW
2.4E-07
2.4B4)7
Cancer
Risk
8.0E-04
S.6B46
4.JE4M
8.IB-04
..
-
--
..
--
-
I.IE-05
2.IB-05
3.2E4S
6.IOB46
2.70E-04
4.6E-I5
5.5E-I4
2.764)4
I.9B-II
I.9B-II
Child Resident
Hazard
Index
8.IB+OI
7.30B-OI
-
8.2B+OI
..
«
-
..
--
--
9.7E-OI
I.4B-00
2.4B+0
5.20B-02
I.23B+OI
5.2B-09
3.35E-IO
I.2E+I
_
-•
Cancer
Risk
I.20E44
2.40B-06
-
I.2B-04
_
.-
--
..
--
--
2.5E-06
9.3E-06
3.4E-05
I.40B-03
3.3B44
4.3E-IS
I.3E-I4
3.4E-04
Adult Employee
Hazard
Index
3.00E-OI
4.30E-02
..
3.4B-OI
..
--
.
«
.-
--
3.7E-02
J.2E-OI
S.6B-OI
2.0B-02
I.7B-00
8E-IO
IE-10
I.7B-00
..
•-
Cancer
Risk
3.00B-06
3.50B47
-
3.56E-06
..
-
-
„
-
-
3.9B-06
1. SB-OS
I.9B-OS
2.30B-06
7.80E-03
2.70E-I5
7.3B-I4
8.0B-OS
M
-
Adolescent
Hazard
Index
_
--
..
-
I.OB-03
I.2B«3
2.2O03
8.4E-04
4.6E-06
8.JBXM
H
..
--
..
—
_
_
-
..
--
Cancer
Risk
..
.-
..
--
I.8E-07
3.0E-07
4.8E-07
7.2E46
3.4E-IO
7.2E-06
..
..
-
„
—
_
_
..
.,
•-
-------
COMPARISON OF ALTERNATIVE COSTS
AIW FRANK/MID-COUNTY MUSTANG
Alternative '
Number .
1. NO ACTON
2. LIMITED ACTIONS
3. PUBLIC WATER
SUPPLY/LIMITED ACTION
4. SOIL • VACUUM
EXTRACTION
A. - AIR STRIPPING
w/DISCHARGE TO
VALLEY CREEK
B. - GAC FILTERS
w/DISCHARGE TO
VALLEY CREEK
C. - AJR STRIPPING
w/DISCHARGE TO POTW
D. - GAC RLTERS
w/DISCHARGE TO POTW
5. SOIL - EXCAVATION
OFFSITE DISPOSAL
A. - AIR STRIPPING
w/DISCHARGE TO
VALLEY CREEK
B. - GAC RLTERS
w/DISCHARGE TO
VALLEY CREEK
C. - AIR STRIPPING
w/DISCHARGE TO POTW
D. - GAC FILTERS
w/DISCHARGE TO POTW
plus.PUBUC WATER
SUPPLY/LIMITED ACTION
Capital
Costs
$0
$ 429,000
$ 2,958,000
$ 177,000
$ 2,380,000
$ 2,247,000
$ 1,800,000
$1,670,000
$ 513,000
$ 2,380,000
$ 2247,000
$ 1,800,000
$1,670,000
$ 2,958,000
Operation &
Maintenance
- $o
$ 872,000
$ 136,000
$ 279,000
$ 5,154,000
$ 10,075,000
$12,218,000
$17,751,000
$0
$ 5,154,000
$ 10,075,000
$ 12,218,000
$ 17,751,000
$136,000
Total Present
Value
$0
$ 1,301,000
$ 3,094,000
$456,000
$ 7,534,000
$ 12,322,000
$ 14,018,000
$ 19,421,000
$ 513,000
$ 7,534,000
$ 12,322,000
$ 14,018,000
$ 19,421,000
$3,094,000
Table 17.
-------
Appendix C
Toxicological Profiles
-------
lexicological Profiles
Trichloroethene; is a colorless, nonflammable, noncorrosive
liquid primarily used as a solvent in vapor degreasing. It is
also used as a dry-cleaning agent, and as a chemical intermediate
in the production of paints and varnishes and other chemicals.
Trichloroethene has low acute toxicity. Chronic inhalation
exposure to trichloroethene has been shown to cause liver,
kidney, and nervous system disorders and skin irritation in
animals. The EPA has classified trichloroethene as a B2-C
carcinogen.
l*l-Dichloroethvlene; caused kidney tumors in male mice, and
leukemia in both male and female mice in separate inhalation
studies. Negative results were obtained in oral studies
involving rats and mice. 1,1-Dichloroethylene is therefore
considered to be a possible human carcinogen. It has been found
to be embryotoxic and fetotoxic in rats.and rabbits via
inhalation. Chronic exposure by rats to low oral doses caused
liver changes. Acute exposure to high doses causes central
nervous system depression.
l.ltl-Trichloro«thana; is a colorless, nonflammable liquid with
an odor similar to chloroform. In recent years it has been used
as a substitute for carbon tetrachloride. In liquid form it is
used as a degreaser and for cold cleaning, dip-cleaning, and
bucket cleaning of metals. 1,1,1-trichloroethane is a solvent
used in dry-cleaning, vapor degreasing, and as a propellant.
1,1,1-Trichloroethane is irritating to the eyes on contact with
either liquid or vapor phases. This effect is usually first
noted in acute exposures. Mild conjunctivitis may develop but
recovery is usually rapid. The solvent's defatting properties
may produce a dry, scaly dermatitis upon repeated contact with
the skin. Acute exposures may lead to dizziness, drowsiness,
increased reaction time, incoordination, unconsciousness, and
death. Inhalation exposure to high concentrations of
1,1,1-trichloroethane depress the central nervous system; affect
cardiovascular function; and damage the lungs, liver, and kidneys
in animals and humans. Mucous membranes may also be irritated by
exposure to this solvent.
Chloroformt has a molecular weight of 119.38, and exists at room
temperature as a clear, colorless liquid with a boiling point of
61.7 C. It is widely used in industry as a solvent, feedstock,
and sterilizing agent, and is found in all chlorinated public
water supplies (because it is a by-product of the chlorination
process). Chloroform is soluble in water, acetone, and non-polar
solvents, and volatilizes readily from solution. It is readily
taken into the body by inhalation, ingestion, and dermal or eye
contact.
-------
Chloroform is a Class B2 carcinogen, because it causes increases
in kidney tumors in rats, and in liver tumors in mice. There is
also suggestive evidence from epidemiological studies that
exposure to chloroform and other trihalomethanes is associated
with an increased incidence of bladder tumors in humans, other
toxic effects of chloroform include central nervous system
depression; eye, skin, and gastrointestinal irritation; and
damage to the liver, heart, and kidney.
Tetrachloroethylene; (PCE) is a clear, colorless, nonflammable
liquid with a characteristic odor. The odor is noticeable at 50
ppm, but may become inconspicuous after a short period of
exposure. PCE is widely used as a solvent in dry-cleaning, as a
chemical intermediate, as a fumigant, and medically as an
anthelmintic.
PCE has been found to cause liver cancer in male and female mice.
Animals exposed to PCE by inhalation may exhibit liver, kidney,
and central nervous system depression. Repeated contact may
cause a dry scaly dermatitis. High concentrations may produce
eye and nose irritation. Symptoms of overexposure include
malaise, dizziness, headache, increased perspiration, fatigue,
staggering gait, and slowing of mental ability... Acute exposure
may cause central nervous system depression, hepatic injury, and
anesthetic death. The EPA considers PCE to be a 52 carcinogen.
Arsenic is a metal that is present in the environment as a
constituent of many organic and inorganic compounds. Arsenic is
a known human carcinogen implicated in skin cancer in humans.
Inhalation of arsenic by workers is known to cause lung cancer.
Arsenic compounds cause chromosome damage in animals, and humans
exposed to arsenic compounds have an increased incidence of
chromosomal aberrations. Arsenic compounds are reported to be
teratogenic, fetoxic, and embryotoxic in some animal species.
Dermatitis and associated lesions are attributable to arsenic
coming into contact with the skin, with acute dermatitis being
more common than chronic. Chronic industrial exposures may be
characterized by hyperkeratosis, and an accompanying
hyperhidrosis (excessive sweating usually of the palms and soles
of the feet).
Manganese is a steel-gray, hard, brittle metal that is
naturally-occurring in the earth's crust. Manganese is used in
the iron and steel industry, and in the manufacture of dry cell
batteries, paints, dyes, matches and fireworks. Although
manganese has a relatively low order of toxicity, chronic
exposure can cause degenerative changes in the central nervous
system. Symptoms of manganese toxicity include apathy, anorexia,
headache, weakness of the legs, irritability, mental confusion,
and aggressiveness. As manganese exposure continues, the
symptoms of toxicity become indistinguishable from classical
Parkinson's disease.
Toluene; has been shown to be embryotoxic in experimental
-------
animals. Chronic inhalation exposures to high levels of toluene
produce central nervous system depression and narcosis in humans.
Chronic exposure to toluene at high concentrations by mammals may
produce cerebellar degeneration and an irreversible
encephalopathy. Co- administration of toluene along with benzene
or styrene has been shown to suppress the metabolism of benzene
or styrene in rats. In humans toluene may cause irritation to
the eyes', respiratory tract, and skin. Acute exposure to toluene
causes central nervous system depression, the symptoms of which
include headache, dizziness, fatigue, muscular weakness,
drowsiness, incoordination with staggering gait, skin
paresthesia, collapse, and coma. Toluene is a clear, colorless,
noncorrosive liquid with a sweet, pungent, benzene like odor.
Toluene may be encountered in the manufactures of benzene. It is
used as a chemical feed for toluene diisocyanate, phenol, benzyl
and benzoyl derivatives,, benzoic acid, toluene sulfonates,
nitrotoluenes, vinyltoluenes, and saccharin. As a solvent,
toluene is used for paints and coatings. It is also used as a
component of automobile and aviation fuels.
vinyl Chloride: is a gas used to manufacture polyvinyl chloride
(PVC) which is contained in many plastic and vinyl products. It
is recognized by the EPA as a class A carcinogen. Chronic
exposure to vinyl chloride has been shown to cause angiosarcoma
of the liver, a form of cancer. Increased risk of cancer of the
brain, lungs, other organs as well as possible miscarriages have
also been associated with inhalation of vinyl chloride. In
humans, acute inhalation exposure to 0.8 to 2.0% vinyl chloride
has been associated with central nervous system depression
resembling mild alcohol intoxication.
-------
Appendix D
Detailed Alternative Costs
-------
Umrtad Action*
CAPITAL COSTS
UntP
S9.ooa.ao js.ooo.oo
sii.oaa.oo sii.aoa.eo
SS.OOOLOB SS.OOD.OO
sii.aoaioa si i.floaoo
S21.000.0a S31.OOB.00
S5.ooo.oa s9.ooa.oo
S9.OBO.Oa S9.000LOO
S400.00 si.9oo.oo
S1.flOO.09 S27.000LOO
S3.ooa.ao sj.ooa.oo
B9000 S1.090.00
u 1800.09 sifjoaaa
20 naoo szoaoe
20 S10.00 S200.00
UTS SI 10.00 S191J9a«
1
S19.12000
I an 20% «
SS9L9M.OO
S3S7J94.09
ST1.479.90
OPBUHON AMD MAMTBUNC*
unit
COM
MOMTOMNO 4NO ANM.T9M
OflwMaorSampftio
Report*
POMT4^U9C CM9JON MLTOI
94 0£fl» S1.rao»
72 S2TQ^O S19.12B.QOJ
120
a SSUB SUKOO
39> SMO.OO S7.900L09
i suoBUB snaoaoo
30
30
30
30
30
30
327.142.00
SS7.49&24
stsxor.a
S113.09X02
st7i.tiajat
SM.129JO
SM.744A
I7J9J07.9T
1140400.97
root C*P«M con
PiMMI WMBI of OtM COM
rOTAl. PRgSCNr VDOtTM CO3T
strur^a
-------
I Conrweten to Pubic Water Supply
Site Nam* AW Frank/Mid County Musing Site
CAPfTAL COSTS
H«m OMCriptian
U"ta Ouanrty Unit Prioa Total Coal
of Water ftfhin
Building Conn*
In.lL
hi. A.
8.800
1.465
S2S5A) J1.S83.000.00
«OJ» S7X2SOA
$2.054.070.00
S410414.00
ConftipMey - Co* BM«( on 20% of SuMott
S2.4S4.8S4.00
Total CapKalCo«t
S2J95T.MOM
OPERATION AND MAINTENANCE
fton Daacrtpbon Tote! Annual * Praaant Worth
" Coal
Subtotal AKtmaUva 2 (3 y*ara only)
Cenonganef . Coat Baaad en 20% of Subtotal
Total
J38.744.00
S7^48JO
S47.882JO
S113J69.78
S22.873JS
S138.043.71
PRESENT WORTH
Total Capital Coat
"racant Worth of (MM Coat
TOTAL PRESENT WORTH COST
J2JS7.ft60.aOI
J1W.043.71
-------
Soil
AJtMTvtfvw 4A
Excavation Off-Ste Trartnant and Oispoaa*. Sol and Subawfec* W;
Sit* Name: AJW Frank/Mid County Mustang Sit*
CAPITAL COSTS
Unit*
Quanity
UnttPrie*
ToMCort
Iwnpsum
S5.000.00 S5.000.00
EXCAVATION. OISPOSM.
Swnpana/AnaJpfc
Tunaportadon
RoadTn
BACKFU. EXCAVATION
tamp cum
ton*
tad
ca-yd.
eu.»d.
eu.yd.
240 $10.00
1 S1.100.00
250 SI .000.00
18 S3.500.00
250 S8.0I
232
232
S1S.OO
S10JO
S2JOOJO
S1.100.00
S2SO.OOO.OO
$83.000.00
Sl.515^0
S3.4COOO
JJJ320-00
Ugal Faaa. Ueano* 4 Pwntta - Co* BaMd on 10% of Capaat
.CoaB«««d on 20% rf Capital
S32W15JO
S3ZB81JO
$85.783.00
ConMnoMiey - Cert
on 20% of SubWri
S427J89JO
S8S317JO
Total CapHal Coat
S513.107.40
PRESENT WORTH
rOTAL PRESENT WORTH COST
SS13.107.40
-------
SJto Nam« AJW FMCIM County Uuttwtg
CAPTTAL COSTS
VAPOK etraACTON SYSTEM MSTAUAHON
simoo tiojoaoo
na.ao suoaaao
saaoaaao Mo.aoaao
moo (•.400.00
sio.aao.oo 110,000.00
naaoaao siaaoaao
OPBUTON AND MAMTENAMCC
SOL VAPOK EXTRACTION AMI TOATMBfT
saio suoaoo
siaoaaoo naooaoo
sziaoo ««tjoo.ao
njoaoo S42.aoo.oo
suooaoo
S125.100.00
-------
14A<1) and 48(1)
Total Erfncttan. Afr Stripping. Dtaehvg* to Surfae* Watar
Ste Nanw AJW Frartcrtlid County Mustang Site
Flow »XOgpm
CAPITAL COSTS
Una
Quamiy
UntPrie*
ToWCoit
Montirinaw**
Liber
lump mm
lump cam
h.ft
houra
GROUWJWATER EXTRACTION
In. (I
Pump TNI
CAW Equipment 4!
GJKXNOWATS* TTOWMBfT
lump earn
lump am
Hft
lump am
lump «um
lump turn
lump eum
fc.ft
1 S2.000.09 SZOOQ.OO
i ts.oooioo a.ooaoo
1100 siiaoo si2i.ooaao
300 $85.00 S19.90000
8S S21CLOO S14.2tOLOO
2800 simao u^zooaeo
330 S8&00 S21.4SaOO
9 SZ800LOO 171400.00
1 S38.000.00 S38.000.00
i sii.ooaoo sii.ooaoo
i si.8oa.oo si.soaoo
1 S10.000J90 S10.000.00
1 S8S.OOO.OO SB6.000.00
200 S32.00 S8.400.00
SHOOO.OO
OBwrGquJemeMti
VAPOR PHASE CAftBON TREATMBIT
•Lit
hmpeun
hmpeum
1000 S3ZOO
- 1 S10.000.00
S10.000.00
S8,OOOlOO S14.000.00
S1.S25.83aOO
SISZSSXOO
S30S.12S.OO
S1.9tU18.00
SZ379.9S2.BO
WNTENANCe
UnitPita* TeMAMHl Tkiw(yn)
GBOUNOWATBIBXTRACTWH AND TREATWWT
S0.10
• r.ioaoo
212 S2BUB S42,«00.00
VA"OR PHMECMVON TRTATMBfr
LONCVTSW MOMTORta
24.000
160
siio S9o.4oaao
sjioioo snaoaoo
St.800.00
SC S21OOO S14.28OOO
120 SS&OO SH600.00
S1S.OOO.OO S19.000.00
29
25
21
30
30
30
S722.810.43
S143JT888
S72Z8ia43
S72&3»t31
S4»3.S8A21
S43.3S&83
S2B1JOO.OO
Cui*ng»«> . Caerrtiim on 20% af
S314.28aOO
StS8.S18.08
SS.tS3.4gAS7
-------
AJtanwdw* 4A<2) tnd 48 (2)
Tot* ExfeKtfon. Garten AdMrpben. Dtochwg* to S«*tac» WMT
S*» Nam«: AJW FwrtWWd County MuMang St»
Ftow "XOgprn
CAPITAL COSTS
UM
GROUNOWATER EXTRACTION
hmpwm
Kft
2.000
330
9
1
S2.000.W
simoo
PumpTwJ
&SHLOO
S0.000.00
kift
kmpavm
GROUMMVATER TREATMSfr
GROUNOMMTBI OaCHAMC
ktft
1 tll.000.00
4.900 nzoo
1 t19.000.00
1 tlO.000.00
1 S500.000.00
4 S43.aao.ao
200 132.00
1 110,00000
1.000 132.00
t tizooaoo
S2.000.00
8441000.00
ei.4saoo
S23LSOO.OO
138,000.00
tll.000.00
(144.000.00
t16.000.00
SI 0.000.00
tsoo.ooo.oo
tl 72,000.00
W.400.00
t10.000.00
SUOOO.OO
t1.440.3H.00
t144.03S.00
S388.070.00
t1.57Z455.00
O74.481.00
l2J4a.W8.00
OPERATION AND MAMTENANCC
Unit .
UniiPne* TaW
GROUNOWATSt EXTRACTION AND TREATMENT
Ctftaflf
160.000
no
LONG-TERM MONrronmo
hem
12.10 ttH.00000 25
S3100 129.600^)0 2S
taio atooaoo 29
• si.ioaoo st.naoo 25
1 tsaooaoo tsaooaao 29
420 S21000 tMJOO.00 29
in S9&00- taaoaoo »
« siaao $i4jaaoo so
120 tsioo saaoaao so
siiooaoo tuooaoo 29
t4.SS5.X2JT
S9202».S1
t143.07BJ*
S72Z610.43
t1JT4.M4.70
S13U2UI
sio3.wr.ci
S S43JS1B
JS90JIO.OO
t11«.OT«.flO
(UM.117JS
S1.67U2349
t70i.4M.00
t10.073J40.71
PfVSSNT
worat era tMCea
rOTAL PRESENT WORTH COST
$10.073.3*a71
I1Z32Z298-"
-------
Gtoun»*ur Atom*** 4*0) «tt 48(3)
TaM Enneaon. Air Sttippna Otaerwg* 10 POTW
So Nam* AIW frwAAM Couly MvMng S«»
300gsn»
CAmAI. COSTS
ou»*r umPnea
9»
Tl
XT* M
Ivlt
OMOUMOMATIII ocnucnoN
1 SS.OOOLOO S&OOOJO
MOO siiaoo IIJI.OOMO
xo MOJO iit.soe.ae
a S310JO tujteae
2000 simoo
O1.440JO
S3SLOOOOO
S11JOO.OO S11JOOLOO
moo *i4*.ooo.oo
S1.000.00 S1.000M
(10^000^00
0X00
BZMXOO
sizoooLoa
M.400LOO
snooaao
t S10040040
t
CMUON THSATMBir
siaoaaoo
tio.ooo.oo
S1.194AOLOO
S113.40UO
IMP
soaooo ta.io
• SltOOOO
212 SZDOOO *a.40B«
1001000 SMI StttJDOLOO
24JOO ttIO
1 SIMOOM SIIJOObOB
ttfl SSKflO
SHJOOJO SttOOOOO
a
a
a
10
10
smiiaa
»14MTtJO
W1Z77JJ4
I72UOU1
S1SWT4JO
Taw Caratrueoon can
>m«nt wo«i or O & H Co*
rOTAL PRESSn-WORTH COST
SI,
Sia217J07.IO
S14AH.UOJO
-------
m
$144,000.00
11*00000
S10LOO&00
OFBUTONANOMAMroUNCf
$0.10
• $1.100100
i $11.000100
HOflOO tUt
$11,000.08
rUMrtLJi
$i9MMa
$ur<«*.»
-------
Alternative 4A
TOTAL COST
CAPITAL COST
Remedy
Component
limited Action
Z. GraundMotar Extoacttan.
J. Soi Excavation, Traetmant
andCfl-SftaObpoaal
Total Capital Coat
GROUNDWATER TREATMENT
AND DISCHARGE OPTION
1. liquid* PIMM
Carbon
1. Oiacnafgato
$428.880.80
SU46.848.00
$513.107.40
$3.16*914.20
OtKRvgato
POTW
$429 MOM
S1.870J70.00
$313.107.40
««».
Vapor - PhaM Carbon
•.a—.
t12fl 0(10 DO
$2479^82.80
$513.107.40
$3,321.951.00
POTW
$428,880.80
$1 800.28880
$513.107.40
S2.74Z255.00
Rafn0O)f
Component
l.tnttuOemCantnM
1 l^^t^^t A«4fa^^
^•TmW MEBBVf
TrMMniMtt vitf OiKlivQft
9* Sol E)BCWVDOfl* TlPMttlMflv
and00-8toOtopa«l
roMOCMCort
OPERATION AND MAINTENANCE
GROUNDWAT&R TREATMENT
AND DISCHARGE OPTION
I.UquU-PtaM
Cutton
LObehvytto
S«0«M«WMr
SS72J97.45
Sia079J4a71
$0.00
i
$10.947.738.15
OtetaQcto
POTW
S87Z387.4S
S17.751.18T.70
$0.00
S18.aS8.5M.1S
2. AJntnppn0 vritti
Vtper- PhaM Caftan
1. DUchaw te
S«atee*WMr
$871387.45
$3,153,488^7
$0.00
$8.025.88401
2.0iwtwr9«to
POTW
S87Z307.4S
I1Z217.887.10
$0.00
119 080.7W 55
PRESENT WORTH
PrwMt Worth of O4M Coat
TOTAL f KESeitT WORTH CU3I
SurtKaWatir
$3.188.914^0
$10.947.738.15
S14.138.8S2JS
POTW
S2.812J38JO
$18.823^5.15
$21^33.933.35
Surtacawatar
$8.023.884.01
$8.347.845.01
2. DtachaiBi to
POTW
SZ742J5100
$13 080 2M 59
-------
Alternate* 48
TOTAL COST
CAPITAL COST
Remedy
Component
l.lntttubanal Control/
UmtodAeMon
Treatment, and DUrt^ga
k *JBJ| WaMMk* B«6«««4f«Mi Yitft^MMfltf
** «**• wpor uwmon* i rwiTivni*
(IfrttU)
Total capital coat
tsKUUNDWATER TREATMfeN 1
AND DISCHARGE OPTION
1.L*uM.phm
Caitaen
1. OfMfWBVtB
Swtee*W«w
942886000
J177710.00
92 8S9 Off? 90
DtaehV9»to
POTW
S4?o nnsQ
$1 .670J70.00
$177^16.00
S&278.44&80
2.AMripping«Mlti
VapAr-PtMMCvtan
1.0lKhw9*lD
Su>tee»Wttar
*<2a.8ao.80
S2J79.982.80
$177718.00
$2.986.030.80
ZOMhMg.tD
POTW
$428.880.80
91 80028880
$177718.00
S2.-40R 38380
Remeoy
Component
1. HMttuHoMieentraM
UnriMAettan
2.Gram*MtarErt»ctfen.
TrMtnMntt sntf OiMlWQv
*• Sew VflpOf GOMBOvX TPMttfMfll*
(Ir»^*u)
rotalO&MCo*
OPERATION AND MAINTENANCE
GROUNDwAl tK TREATMENT
AND DISCHARGE OPTION .
1.UquU>niM*
Cwban
1. OiMtagcta
SwteMWMr
. $872487.45
$10.07*340.71
$279J»4.00
$11728.792.15
Ditcti«fg»to
POTW
$871387.4$
$17.781.187.70
$27>.054.00
$18J02.849.15
2* AintrippinQ wM)
Viper •PhM*C«ben
1.0tehvg*te
SurtK*W«Mr
$87X397.45
$5.153.48857
$279,054.00
SO 304 048 01
2.0bdwrg»to
POTW
$87Z367.4S
112717.897.10
$279.054.00
I13J66.34855
PRESENT WORTH
Total dpi* Cort
PTMOTI Worth of OAM Co«
TOTAL PRESENT WORTH COST
1. DRKtargcM
Surtee* Water
$11728.792.15
$14.079.614.95
Diachatgcto
POTW
. $2776.448.80
$18.902.648.15
$21.179.085.95
1.DoehafB»to
Swtae«Watar
$2486.059.60
$6.304.948.01
$9791.007.61
2.0iactarg«te
POTW
$2.406.363.60
$13.369.346.55
$15.775.71115
-------
Drum and Sump Removal Detailed Cost Estimate
Estimated Capital Costs: $ 57,816
Estimated Total O&M Costs: $ 0
Estimated 30 Year Total present Worth Costs: $ 57,816
Item Description Total Cost
Excavation of Sump $ 5,000
Disposal of Drums (4) $ 1,600
Disposal of Sump and Contents $ 27,000
Sampling & Analysis $ 5,000
Transportation $ 1,050
Backfill S 500
Subtotal $ 40,150
Engineering and Administration $ 8.030
(20% of Subtotal)
Subtotal $ 48,180
Contingency (20% of Subtotal) $ 9.636
Total Costs 8 57.816
-------
Additional Ecological Assesment Detailed Cost Estimate
Estimated Capital Costs: $ 48,240
Estimated Total O&H Costs: $ 0
Estimated 30 Year Total Present Worth Costs: $ 48,240
Item Description Total Cost
Endangered Species Survey $ 5,000
Sampling & Analysis $ 15,000
Grading $ 10,000
Excavation $ 1,500
Backfill $ 1,000
Transportation $ 500
Revegetation $ 500
Subtotal $ 33,500
Engineering and Administration $ 6.700
(20% of Subtotal)
Subtotal $ 40,200
Contingency (20% of Subtotal) $ 8.040
Total Costs s 48,240
-------
Provision of Carbon Filtration Units De-tailed Cost Estimate
Estimated Capital Costs: $ 6,000
Estimated Total O&M Costs: $ 13,500
Estimated 30 Year Total Present Worth Costs: $19,500
capital Costs
Item Description Total Cost
Carbon Filtration Units (5) S 6.000
Subtotal $ 6,000
Operation & Maintenance
Item Description Total Cost
Sampling & Analysis (3 Yrs) $ 10,500
Carbon Replacement
(once per year for 3 Yrs) $ 3.000
Subtotal $ 13,500
Total Costs $ 19.500
-------
APPENDIX E
RESPONSIVENESS SUMMARY
FOR THE PROPOSED REMEDIAL ACTION PLAN
AT THE
AIW FRANK/MID-COUNTY MUSTANG SUPERFUND SITE
EXTON, PENNSYLVANIA
Public Conment Period:
June 16, 1995 thru August 15, 1995
-------
AIW FRANK/MID-COUNTY MUSTANG SITE
RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION PLAN
TABLE OF CONTENTS
Overview 1
Background 2
Part I: SUMMARY OF COMMENTORS' MAJOR ISSUES AND CONCERNS ... 3
A. Treated Water Discharge Issues 4
B. Implementation of the Remedy *. 8
c. Health concerns ••..-... ..-.' 9
PART II: COMPREHENSIVE, TECHNICAL, AND LEGAL RESPONSE TO
COMMENTS 10
A. Comments of Duane, Morris & Heckscher on behalf of CDS
Investments 10
B. Comments of Stevens & Lee on behalf of Lewis and Ruth
Frame 13
c. Comments of valley Forge Chapter of Trout unlimited
18
D. Comments of West Chester Fish, Game i wildlife
Association . 19
E. Comments of West Whiteland Township officials ... 20
F. Comments of Brandywine Conservancy 30
6. comments of Clean Water Action 31
H. Comments of West Chester Area Municipal Authority . 32
-------
RESPONSIVENESS SUMMARY
AIW FRANK/MID-COUNTY MUSTANG SITE
EXTON, PENNSYLVANIA
This community relations responsiveness summary is divided
into the following sections:
Overview: This section discusses EPA's preferred alternative
for remedial action.
Background: This section provides a brief history of community
interest and concerns raised during remedial
planning at the AIW Frank/Mid-County Mustang Site.
Part I: This section provides a summary of commentors'
major issues and concerns, and expressly
acknowledges and responds to those raised by the
local community. "Local community11 may include
local homeowners, businesses, the municipality,
and potentially responsible parties (PRPs).
Part II: This section provides a comprehensive response to
all significant comments and is comprised
primarily of the specific legal and technical
questions raised during the public comment period.
If necessary, this section will provide technical
detail to answers responded to in Part I.
Any points of conflict or ambiguity between information provided
in Parts I and II of this responsiveness summary will be resolved
in favor of the detailed technical and legal presentation
contained in Part II.
Overview
On June 16, 1995, EPA announced the opening of the public
comment period and published its preferred alternative for the
AIW Frank/Mid-County Mustang Site, located in Exton, Chester
County, Pennsylvania. EPA screened several possible alternatives
to remediate the Site contamination, giving consideration to nine
key evaluation criteria:
• Threshold criteria, including;
—Overall protection of human health and the environment;
—Compliance with Federal, state, and local environmental
and health laws;
• Balancing criteria, including;
—Long-term effectiveness and permanence;
—Reduction of mobility, toxicity, or volume of
contaminants;
-------
—Short-term effectiveness;
—Ability to implement;
—Cost; and
• Modifying criteria, including;
—State acceptance; and
—Community acceptance.
EPA carefully considered state and community acceptance of the
remedy prior to reaching the final decision regarding the remedy.
The Agency's preferred remedy is outlined below. Based on
current information, this alternative provides the best balance
among the alternatives with respect to the nine criteria EPA uses
to evaluate each alternative. The selected remedy consists of
the following components:
1. Extraction and treatment via air stripping of
groundwater with vapor phase carbon adsorption and
subsequent discharge to either: l) West Valley Creek,
2) the on site pond, or 3) West Whiteland spray
irrigation POTW, following a predesign hydrogeologic
investigation;
2. Excavation and off-site disposal of contaminated soils,
following predesign soil investigations;
3. Installation of a water line;
4. Removal, decontamination and off-site disposal of drums
and sump;
5. Structure Demolition/Restoration
6. Institutional controls
7. Performance of an Additional Ecological Assessment;
8. Provision of Point of Use Carbon Filtration Units
(until waterline is extended)
9. Performance of a Phase I archeological survey prior to
any intrusive remedial activities.
10. Long Term Ground Water Monitoring.
Background
Community interest and concern about the Site has been steady
throughout EPA involvement. EPA issued a Fact Sheet in October,
1990 which provided information concerning the removal and off
site disposal of approximately 30 drums containing primarily
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methylene chloride. The October, 1990 Fact Sheet also provided
information regarding the Superfund clean up process and
activities which would take place at the Site.
On July 8, 1991, a Community Relations Plan was completed for the
Site. The Plan highlighted issues, concerns and interests of the
community located near the Site which were raised during
interviews.
EPA issued a Fact Sheet in July 1992, providing an update of Site
activities including planned field work for the Remedial
Investigation and Feasibility Study ("RI/FS"). The Fact Sheet
also announced a public meeting, which was held on August 5,
1992. The public meeting provided information to interested
parties regarding the RI/FS field work which was about to begin
at the Site.
In October, 1993 EPA issued a Fact Sheet to keep the community
informed of Site related activities. The Fact Sheet briefly
explained the initial findings of the RI, the Superfund Process,
and the nature and extent of Site contamination.
Pursuant to CERCLA § 113(k)(2)(B)(i)-(v), the RI/FS reports and
the Proposed Plan for the AIW Frank/Mid-County Mustang Site were
released to the public for comment on June 16, 1995. These
documents were made available to the public in the Administrative
Record located at the EPA Docket Room in Region Ill's
Philadelphia office, and the West Whiteland Township Building,
Exton, Pennsylvania. The notice of availability of these
documents was published in the Chester County Daily Local News
and the Philadelphia Inquirer Chester County Neighbors Section on
June 16, 1995.
A public comment period on the,, documents was held from June 16,
1995 to July 17, 1995. A timely request for a 30-day extension
to the public comment period was made on June 28, 1995. As a
result, the closing date for the public comment period was
extended to August 15, 1995. In addition, a public meeting was
held on June 29, 1995. At this meeting, representatives from EPA
answered questions about conditions at the Site and the remedial
alternatives under consideration. Also, on July 20, 1995,
representatives of EPA met with a local civic association to
answer questions about the remedial alternatives under
consideration.
Part I: SUMMARY OF COMMENTORS' MAJOR ISSUES AMD CONCERNS
This section provides a summary of commentors' major issues
and concerns, and expressly acknowledges and responds to those
raised by the local community. The major issues and concerns
about the proposed remedy for the AIW Frank/Mid-County Mustang
Site received at the public meeting on October 19, 1994, and
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during the public comment period, can be grouped into three
categories:
A. Treated Water Discharge Issues
B. Implementation of the Remedy
C. Health Concerns
The questions, comments, and responses are summarized below.
A. Treated Water Discharge Issues
1. How will the volume of water being discharged affect the
level of West Valley Creek.
EPA Response; Based on comments received during the public
comment period, EPA has considered alternative discharge
options for the treatment system discharge including: l)
discharge to West Valley Creek as described in the proposed
plan; 2) discharge to the on Site pond; and 3) spray
irrigation of the treated water in the proposed West
Whiteland Totms.hip spray irrigation POTW system. The final
discharge method could be any one or a combination of the
three options described above. A complete discussion of
these discharge options can be found in Section XI.A. of the
ROD. Discharge to West Valley Creek has-been retained as an
option, primarily because of the thermal mitigation benefits
(i.e. discharging cool treated water directly to the Creek)
it would provide in the event that the extraction system
does impact the thermal regime of West Valley creek.
Thus it is possible that in implementing the remedy EPA
may not discharge directly to West Valley Creek. However,
in the event that this option is implemented, the exact
amount of water that will be discharged will vary during the
operation of the pump and treat system. The actual capacity
of the pump and treat system will be determined during the
Remedial Design. The Proposed Plan estimated that the
system would treat a maximum of 300 gallons per minute
("gprn") . Based on comments received during the public
comment period., EPA conducted a more detailed design like
reevaluation of the volume of water to be treated. As a
result, it is currently estimated that the system will
routinely treat and discharge approximately 140 gpm. This
translates into slightly more than 200,000 gallons per day.
West Valley Creek currently has a flow rate of .465 cubic
feet per second ("cfs") at the discharge point contemplated
in the Proposed Plan, during typical low flow conditions
(mid to late summer) . The stream is 6.4 feet wide at that
location and during low flow conditions contains
approximately 13/4 inches of water. The 140 gpm discharge
translates into an additional flow of .307 cfs, which would
account for 39% of the total stream flow during low flow
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conditions. The depth of water in the Creek at the
discharge location would likely increase by 3/4 to i inch,
again during low flow conditions. During normal and high
flow conditions the percent increase in flow due to treated
effluent discharge would significantly decrease.
2. Was spray irrigation of the treated water discharge
evaluated by EPA?
EPA Response; Spray irrigation was not specifically
evaluated by EPA in the Feasibility Study Report. However,
based on comments received during the public comment period,
EPA has considered alternative methods for the treatment
system discharge including spray irrigation. Spray
irrigation could potentially provide an alternative to
direct stream discharge and provide for aquifer recharge.
'However, EPA has learned tha^t most spray irrigation systems
in operation do require a limited stream discharge under
certain conditions to control costs. The proposed West
Whiteland spray irrigation POTtf is in the conceptual design
phase, therefore, at this time, EPA does not have enough
detailed information to accurately weigh this discharge
option against the other discharge alternatives. However,
EPA has selected spray irrigation through the West ffhiteland
POTW system as one of the discharge points it may utilize as
part of the Selected Remedy. If after more detailed
information is available it is determined during the
remedial design that spray irrigation provides the best
balance of tradeoffs when weighed against the other two
discharge point options it will be incorporated into the
design and implemented.
3. Can the treated water be discharged to the Pennsylvania
Department of Transportation ("PENNDOT") wetlands mitigation
project, or to the ponds in the vicinity of the Site?
EPA Response; Possibly. However, discharge to the PENNDOT
wetlands mitigation areas was not specifically evaluated by
EPA in the Feasibility Study Report. Based on comments
received during the public comment period, EPA has
considered alternative methods for the treatment system
discharge including discharge to the on site pond. The
potential benefits to discharging to the PENNDOT wetlands
area would include avoidance of direct discharge to West
Valley Creek and partial recharge of the aquifer. However,
discharge to the on site pond provides the same benefits
regarding avoidance of direct discharge to West Valley Creek
and partial recharge of the aquifer though the pond area and
through the intermittent portion of West Valley Creek just
west of the pond and east of Ship Road, while minimizing the
impacts on the wetlands areas on and off site. Discharge to
the on site pond would reduce the eventual total amount of
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discharge directly to West Valley Creek through evaporation,
as well as, through ground water recharge. Discharge to the
on site pond is still dependent on the attainment of the
NPDES effluent discharge requirements established by PADEP.
4. Was reinjection of the treated water discharge evaluated by
EPA?
EPA Reaponse; Reinjection of the treated water discharge
was not specifically evaluated by EPA in the Feasibility
Study Report. However, based on comments received during
the public comment period, EPA has considered alternative
methods for the treatment system discharge including
reinjection. Deep well reinjection was suggested as a
method of restoring the ground water aquifer and preventing
direct discharge to West Valley Creek. EPA agrees that
partially restoring the aquifer and avoiding total stream
discharge are objectives whj.ch are very important to this
community. However, the Agency feels that the discharge
options chosen in the Selected Remedy will accomplish the
best balance of tradeoffs.
Discharge to the on site pond will partially restore
the aquifer, as well as, limit the amount of direct
discharge to West Valley Creek. Discharge to the proposed
West Whiteland POTW if it is ultimately utilized would also
accomplish these objectives. Discharge via reinjection
would be a costly and possibly technically challenging .
discharge option. The additional wells and piping involved
would essentially double the costs of those items when
compared to the discharge options under the Selected Remedy.
Also, reinjection in the karst geology of the region may
have a more unpredictable effect than the more natural
aquifer replenishment of spray irrigation or discharge to
the on site pond.
5. Is the sale of the treated water to Philadelphia Suburban
Water Company an option for EPA?
EPA Response; Sale of the treated effluent to Philadelphia
Suburban Water Company ("PSWC") was not specifically
evaluated by EPA in the Feasibility Study Report. However,
based on comments received during the public comment period,
EPA contacted and provided detailed information regarding
the extraction and treatment system proposed to
representatives of PSWC, to determine their potential
interest in such an arrangement. In a letter dated August
17, 1995 PSWC responded to EPA's inquiry. In summary the
letter states, "... PSWC could not at this time seriously
entertain a proposal to use the discharge from the ground
water remediation as a potable water source. The disparate
goals of ensuring a high quality public water supply and
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achieving site clean up under strict EPA requirements
present serious complications and obstacles (technical,
legal and political)' to such a proposal." Therefore, EPA
has determined that sale of the treated water discharge is
not an implementable option. A complete copy of the August
17, 1995 PSffC letter can be found in the Administrative
Record.
6. Will the extraction of ground water and discharge to a
location which does not recharge the aquifer as contemplated
in the Proposed Plan cause the collapse of existing
sinkholes and create additional sinkholes in the area?
EPA Response; EPA understands and recognizes the particular
concern of citizens and the local municipality regarding
sinkholes in this area. It should be recognized that
discharge to West Valley Creek would provide for limited
recharge of the aquifer west of the discharge location
described in the proposed plan. Additionally, EPA
recognized the potential for sinkholes in the vicinity of
the Site during the remedial investigation and specifically
contracted with the United States Geological -Survey ("USGS")
to provide expert assistance in developing regional and site
specific geological information which was presented in the
Remedial Investigation Report and used in the Feasibility
Study Report. The remedial investigation efforts
specifically noted that there are what appear to be a few
scattered sinkholes located to the southwest of the study
area. More recently, EPA has noted the development of a
sinkhole west of the site. However, collection of ground
water through extraction wells is a highly reliable, proven
technology, commonly used to remediate ground water
contamination in areas with similar geologic conditions as
the Site.
The extraction system will be designed using existing
historic regional hydrogeologic data along with the Site
specific data collected during the Rl and predesign studies
to develop well formulas to describe flow conditions and
calculate drawdown at the well and the radius of pumping
influence. The well formulas are used to calculate
cumulative drawdown curves, which are then used to determine
the number, location of wells (well spacing) and pumping
rates required to contain contaminant migration while not
significantly drawing down the ground water table in any one
location. By not significantly drawing down the water table
in any single location the possibility of the formation of
sinkholes is greatly reduced. Also, discharge options in
the selected remedy including discharge to the on site pond
and spray irrigation would provide for partial aquifer
recharge which could further reduce the potential for
sinkholes.
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7. What thermal effects will the extraction and treatment
system have on West Valley Creek?
EPA Response; EPA understands and shares the concern that
citizens have regarding the protection of the water quality,
and recreational uses of West Valley Creek. As a cold water
fishery downstream of the Site, West Valley Creek has strict
temperature and dissolved oxygen content requirements which
the discharge must meet. The requirements are part of the
NPDES permitting requirements, which are established by the
Pennsylvania Department of Environmental Protection and are
required to be met. Effluent and downstream temperature
sampling will be required prior to and during the operation
of the system in order to ensure that the thermal conditions
of the stream are not altered. The exact number and
locations for downstream sampling will be determined during
the Remedial Design. If sampling data indicates that
conditions in the stream may be altered by the treatment
system, actions will be taken to assure that the treated
effluent discharge will comply with the NPDES requirements
listed as ARARs to the ROD.
B. Implementation of the Remedy
1. Several citizens requested a time frame for the cleanup.
EPA Response; Once the Record of Decision has been issued,
the Remedial Design (the detailed implementation plan) for
accomplishing the Site cleanup will begin. For some
portions of the selected remedy (i.e. the ground water
extraction and treatment system) the Remedial Design could
take over a year to develop. Other portions of the selected
remedy may be able to be designed and implemented more
quickly. The Remedial Action, which is the actual cleanup,
can begin as soon as the Remedial Design is complete. At
this point in time, EPA cannot anticipate exactly how long
the Remedial Action will take, however, it is estimated that
the ground water extraction and treatment system will
operate for 25 to 30 years.
Following remedial design the installation of the
waterline should take approximately 6 months. Similarly,
the drum and sump removal, building demolition/restoration,
as well as, the soil excavation remedial actions should take
approximately 6 months to one year to implement after the
remedial design is complete.
A schedule for cleanup activities will be developed
during the Remedial Design. EPA will keep citizens informed
of the time table for implementation of the selected remedy
through distribution of fact sheets and periodic public
meetings.
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2. Will there be 24 hour surveillance by an engineer/chemist on
Site during the operational years of the system?
EPA Response; The air stripping treatment system will be
designed to operate unattended on a 24 hour per day basis
for approximately 25 to 30 years. There will be periodic on
site operation and maintenance of the system (typically 3-4
hours per day) by a qualified contractor throughout the
systems' operation to ensure the proper operation of the
system and to collect the required influent and effluent
water and air emissions samples for analysis. Typically,
the operation and maintenance contractor will be on site on
a part time daily basis and then provides a twenty four hour
on call service in the event any system alarms have
occurred.
3. What protective measures are in effect in the event there is
a failure by the system to extract pollutants?
EPA Response; In the event that the system fails to extract
pollutants from the influent ground water or effluent air as
designed the system will be shut down until such time that
the cause of the failure can be determined and repaired.
c. Health Concerns
1. What will be the quality of the water discharged into West
Valley Creek?
EPA Response; EPA understands and shares the concern that
local citizens have regarding the protection of the water
quality of West Valley Creek. As a cold water fishery
downstream of the Site, West Valley Creek has strict water
quality, temperature and dissolved oxygen content
requirements which the discharge must meet. The
requirements are part of the NPDES requirements, which are
established by the Pennsylvania Department of Environmental
Protection and are required to be met as ARARs for the
Selected Remedy. The NPDES discharge requirements include
limits on total suspended solids, total dissolved solids,
pH, metals and organic contaminants. Many of the limits
meet or exceed drinking water standards, however, others do
not, such as, the total dissolved solids and total suspended
solids limits. While these limits will be protective of the
aquatic life in the stream they would not be acceptable for
a potable water supply. It is expected that the air
stripping treatment system will accomplish at least 99%
removal of all site related contaminants, and that the
resulting treated effluent will comply with the NPDES
requirements.
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2. How frequently will the air be monitored to protect the
population?
EPA Response; Contaminants in the emitted air from the air
stripping system will be captured by a vapor phase carbon
adsorption unit. Air emissions from the air stripping tower
must be reduced to the minimum attainable level through the
use of the Best Available Technology (BAT), 25 PA Code §
127.12(a)(5). Those regulations require that emissions be
reduced to the minimum levels possible. At these levels any
residual risk posed by emissions from the air stripping
tower are far below the acceptable risk level established by
EPA of 1.0 x 10^ (or 1 in 1,000,000). The vapor phase
carbon adsorption units will be monitored (twice per month)
and replaced on a periodic basis which will ensure that no
contaminant breakthrough will occur.
PART II: COMPREHENSIVE, TECHNICAL, AND LEGAL RESPONSE TO
COMMENTS
This section provides technical detail in response to
comments or questions on the AIW Frank/Mid-County Mustang Site.
These comments or questions were received at the June 16, 1995
public meeting or by mail or telephone during the public comment
period, and may have been covered in a more general fashion in
Part I of this Responsiveness Summary. The following specific
comments are addressed:
A. Comments of Duane, Morris & Heckscher on behalf of COS
Investments
B. Comments of Stevens & Lee on behalf of Lewis and Ruth Frame
C. Comments of Valley Forge Chapter of Trout Unlimited
D. Comments of West Chester Fish, Game & Wildlife Association
E. Comments of West Whiteland Township officials
F. Comments of Brandywine Conservancy
G. Comments of Clean Water Action
H. Comments of West Chester Municipal Authority
I. Comments of Pennsylvania Department of Environmental
Protection
A. Commits of Duane, Morris t Heckscher on behalf of CDS
Investments
In an 8-page document dated July 13, 1995, Duane, Morris &
Heckscher commented on the Proposed Plan on behalf of CDS
Investments. The document included several specific legal and
technical comments regarding the Proposed Plan. These specific
legal and technical comments follow:
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1. The proposed plan bases the selection of Alternative 5 on
assumptions about exposure which are unfounded and
inconsistent with CERCLA, Pennsylvania's Land Recycling and
Environmental Remediation Standards Act (Act 2 of 1995), and
U.S. EPA OSWER Directive No. 9355.7-04, entitled "Land Use
in the CERCLA Remedy Selection Process." In so doing, the
proposed plan fails to meet the CERCLA threshold criteria of
compliance with ARARs.
a. Apart from explaining that several ground water wells
exist, the Proposed Plan is devoid of any factual information
concerning actual exposure or planned future land use which would
result in exposure. *
EPA Response; Although they are not ARARs, EPA has carefully
considered Act 2 of 1995 and the cited U.S. EPA OSWER Directive
during the remedy selection process. To EPA's knowledge the
current zoning of the AIW Frank portion of the Site property is
zoned for commercial/light industrial use. However, the Mid-
County Mustang portion of the Site is currently a mixed
residential/commercial property with two residential dwellings
along with Rex Carle Automotive and the former Pipe Maintenance
Service buildings. In fact, the nearest residential dwelling is
less than 30 feet from the Site boundary and the most highly
contaminated monitoring well (MW-108). Also, there are no
controls in place to limit the future rezoning for residential
use of the Site properties. The Risk Assessment performed for
the Site evaluated the potential risk associated with current
land use and future use regarding exposure to on site residents
and employees. EPA believes that the Baseline Risk Assessment
properly characterizes current and future exposure at the Site.
The entire Baseline Risk Assessment which can be found in the
Remedial Investigation Report was placed in the Administrative
Record for the AIW Frank /Kid-County Mustang Site prior to the
Proposed Plan comment period and has since been available for
review. The proposed plan and Record of Decision correctly
summarized the risks associated with exposure at the site and
carefully considered ACT 2 of 1995 and the cited OSWER Directive.
b. To the extent that the Proposed Plan does not include
Pennsylvania's Land Recycling and Environmental Remediation
Standards Act (Act 2 of 1995), it is defective on this basis
alone.
EPA Response; On page seven (7) of the Proposed Plan in the
Section titled "Maior ARARs for the site" the following is set
forth: Currently, the Commonwealth of Pennsylvania relevant and
appropriate standards for ground water specify that all ground
water containing hazardous substances must be remediated to
"background" quality pursuant to 25 PA code §§ 264.97 (i) , (j),
and 264.100(a)(9). Nonetheless, Pennsylvania Senate Bill #1
(SB1), referred to as the Land Recycling and Environmental
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Remediation Standards Act was signed into law by Governor Ridge
on May 19, 1995 and became effective on July 19, 1995. Act 2 of
1995 was not effective at the time of issuance of the Proposed
Plan, nevertheless, it was considered by EPA even though the
Commonwealth of Pennsylvania did not identify it as an ARAR at
that time. EPA has had time to review and evaluate the
applicability of Act 2 to the selected remedy. EPA does not
consider the Land Recycling and Environmental Remediation
Standards Act to be an ARAR for the AIW Frank/Mid-County Mustang
Site at this time. The Record of Decision for the Altf Frank/Mid-
County Mustang Site does properly present and the Selected Remedy
will attain the substantive requirements of all ARARs. See
Section XI.B. of the Record of Decision for a discussion of Act
2.
2. The proposed plan fails to give appropriate weight to the
CERCLA primary balancing criteria of implemeritability and
cost, and fails to comply with U.S. EPA OSWER Directive
9234.2-25, entitled "Guidance for Evaluating the Technical
Impracticability of Ground Water Restoration."
EPA Response: EPA has given the appropriate weight to the CERCLA
balancing criteria of implementability and cost in the proposed
plan and further in the Record of Decision for the Site. Based
on current information, which can be found in the Administrative
Record for the Site, the Selected Remedy described in the Record
of Decision for the AIM Frank/Mid-County Mustang Site provides
the best balance among the alternatives with respect to the nine
criteria EPA uses to evaluate each alternative.
Further, the Record of Decision does properly comply with
the cited OSWER Directive by directly addressing the technical
impracticability issue in the following manner. If EPA, in
consultation with the Commonwealth of Pennsylvania, determines
that implementation of the selected remedy demonstrates, in
corroboration with hydrogeological and chemical evidence, that it
will be technically impracticable to achieve and maintain the
performance standards throughout the entire area of the
contaminant plume, EPA, in consultation with the Commonwealth may
require that any or all of the following measures be taken, for
an indefinite period of time, as further modification(s) of the
existing system:
a) long-term gradient control provided by low level pumping, as
a containment measure;
b) chemical-specific ARARs may be waived for those portions of
the aquifer that EPA, in consultation with the Commonwealth
determine that are technically impracticable to achieve further
contaminant reduction;
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c) institutional controls may be provided/maintained to restrict
access to those portions of the aquifer where contaminants remain
above performance standards; and
d) remedial technologies for ground water restoration may be
reevaluated.
The decision to invoke any or all of these measures may be made
during implementation or operation of the remedy or during the 5-
year reviews of the remedial action. If such a decision is made,
EPA shall amend the ROD or issue an Explanation of Significant
Differences.
B. Comments of Stevens & Lee on behalf of Levis and Ruth Frame
In a 7-page document dated August 16, 1995, Stevens & Lee
commented on the Proposed Plan on behalf of Lewis and Ruth Frame.
Also submitted was a 17 page document of specific technical
comments on the RI/FS and Proposed Plan prepared by consultants
for Lewis and Ruth Frame. Together the documents include
specific legal and technical comments regarding the Proposed
Plan. These specific legal and technical comments follow:
EPA's proposed decision to extract, treat and discharge
contaminated ground water at the Site into West Valley Creek
may be impracticable, and is arbitrary, capricious, an abuse
of discretion, not in accordance with law, and unsupported
by the evidence in EPA's administrative record.
a. Provision of public water to the 12 residences and
businesses affected or potentially affected by groundwater
contamination eliminates the need for a groundwater
extraction, treatment and. discharge system.
EPA Response: Several requirements apply to this important water
resource. The National Contingency Plan (*NCP*) at 40 C.F.R.
Section 300.430 requires that ground water be restored to its
beneficial use, which at the AIW Frank/Mid-County Mustang Site is
a current drinking water supply, as properly noted in the
Proposed Plan and ROD. Also, the Selected Remedy must meet all
ARARs which require remediation of ground water to MCLs.
b. EPA has not properly identified the source of
groundwater contamination at the Site.
EPA Response: The data collected during the Remedial
investigation ("RI"), which can be found in the administrative
record clearly identifies the source of ground water
contamination. The Alff Frank/Mid-County Mustang RI clearly
identifies a plume of TCE and 1,1,1 TCA, as well as other
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volatile contaminants with a source area on the Alff Frank/Mid--
County Mustang Site properties. The ground water data from the
RI shows the highest concentration of 1,1,1 TCA (796 ppb) in Mff-
106 which is just a few feet from the former Alff Frank
Corporation's above ground solvent tank location. 1,1,1 TCA is
known to have been used as a solvent by the Alff Frank
Corporation. 'Mff-108, which is located near the former Mid-
County Mustang/Pipe Maintenance Service underground tile field,
was the most highly contaminated well sampled. TCE was detected
at 6,850 ppb, and cis-1,2 dichloroethylene was detected at 10,400
ppb in Mff-108. From the source location on site, the plume
extends approximately 1/2 mile to the west along Exner Lane with
the concentrations of these same contaminants decreasing the
farther from Mff-106 and Mtf-108 that samples were collected.
Upgradient (background) monitoring wells and residential wells
such as Mff-101 and the "Drexel Heating" well, which are located
downgradient of the former Autocar facility and upgradient of the
Site did not show any level of detection for these contaminants.
Thus it is appropriate to conclude that .the Site properties are
source areas for the contamination.
c. EPA's risk assessment in the RI/FS concerning the
groundwater contamination at the Site is called into
question by certain internal EPA and ATSDR documents.
EPA Response: In 1992, the EPA Remedial Project Manager assigned
to the Alff Frank/Mid-County Mustang Site requested the Superfund
Removal Program to evaluate the necessity of conducting an
emergency removal action to extend existing water lines to
residents and businesses affected by the Alff Frank/Mid-County
Mustang contaminant plume. An analysis of the existing ground
water data at that time indicated that there was not an imminent
threat to human health or the environment posed by ground water
which would require an immediate removal action. However, EPA's
toxicologist did at that time determine that a long term or
chronic threat to human health existed and that long term
remedial action was necessary. The Remedial Investigation ("RI")
which was performed from 1993 to 1995, included additional
sampling and analysis results which were used to perform a
Baseline Risk Assessment which indicated that there is an
increased risk to future on site adults and children due to the
ingestion and inhalation of contaminated ground water at the
Site. The RI which includes the sampling results and the
Baseline Risk Assessment is in the Administrative Record for the
Site.
d. The levels and areal extent of groundwater contamination
appear to be diminishing.
EPA Response: EPA agrees that when sampling results from 1982
are compared to sampling results from the RI the plume does
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appear to have diminished to some degree. However,
concentrations of contaminants in wells in close proximity to the
Site have shown fairly steady levels of contamination over time.
EPA cannot predict whether this trend will continue.
e. Maximum Contaminant Levels ("MCLs") under the Safe
Drinking Water Act should not be considered Applicable or
Relevant and Appropriate Requirements ("ARARs") for
groundwater at this Site.
EPA Response: As properly stated in the proposed plan and ROD,
EPA has classified the affected aquifer at the Site as a Class
HA aquifer, a current source of drinking water, in accordance
with the EPA Document "Guidelines for Groundwater Classification:
(Final Draft, December 1986) ". The concentrations of
contaminants in the ground water at the Site are above Maximum
Contaminant Levels ("MCLs") which are enforceable, health-based
drinking water standards established under the Safe Drinking
Water Act ("SffDA"), 42 U.S.C. §§ 300f to 300J-26. '
f. EPA has not properly determined the cost of the
groundwater extraction, treatment and discharge system.
EPA Response: The assumptions made in the Feasibility Study
Report ("FS") regarding the ground water extraction, treatment
and discharge system are consistent with prior experience and
standard engineering practice. If dense non-aqueous phase liquid
("DNAPL") is present (See Section V.B.9. of the Record of
Decision for discussion of DNAPL), which EPA does not believe to
be the case, and which will be further evaluated during predesign
hydrogeologic studies, the cost of the extraction and treatment
may increase and/or the remedy may have to be modified. The ROD
specifically addresses such a determination (See Section
IX.B.I.e.) Further, see response in Part II, Section A, response
#2 above. The Feasibility Study Report is in the Administrative
Record for the Site.
g. EPA's proposed groundwater extraction, treatment and
discharge system may have adverse impacts upon the West
Valley Creek, nearby wetlands, and the surrounding
community.
EPA Response: See responses in Part I, Section A of this
responsiveness summary and Section IX.B.I of the Record of
Decision.
h. EPA did not properly evaluate the 9 remedy selection
criteria required by the National Contingency Plan.
EPA Response: EPA carefully and appropriately evaluated the nine
(9) remedy selection criteria required by the NCP prior to
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reaching the remedial action decision presented in the Record of
Decision. See Section VIII. SUMMARY OF COMPARATIVE ANALYSIS OF
ALTERNATIVES of the Record of Decision. Further, based on
current information, which is in the Administrative Record for
the Site, the Selected Remedy described in the Record of Decision
for the AIW Frank/Mid-County Mustang Site provides the best
balance among the alternatives with respect to the nine (9) NCP
criteria EPA uses to evaluate each alternative.
i. EPA's RI/FS is deficient in several key areas and
seriously calls into question the lawfulness and credibility
of the Proposed Plan.
•
EPA Response: EPA does not believe that the Remedial
Investigation and Feasibility Study reports (* RI/FS") prepared
for the Site are deficient. The RI/FS for the Alfi Frank/Mid-
County Mustang Site was conducted in accordance with EPA guidance
and policies. Work plans for these activities were thoroughly
reviewed and approved by EPA in consultation with PADEP. These
plans were developed based on a review of historical data, site
visits, and the results of discussions held among EPA, PADEP and
USGS during the RI/FS scoping process.
The goals of the RI/FS were to characterize the nature and
extent of environmental contamination due to past practices at
the Site, characterize any current or future risks to human
health and the environment posed by the Site, and evaluate
potential remedial measures to clean up the Site. EPA believes
that these goals were met by the final April, 1995 Alff Frank/Mid-
County Mustang Site RI/FS reports.
The RI for the Site clearly identifies a ground water plume
of TCE, and 1,1,1 TCA, as well as several other VOCs, with a
source area on the Alff Frank/Mid-County Mustang Site properties.
See EPA response presented in Part II, Section B, Comment (b) .
Likewise, the RI report establishes that an area of elevated
chemical concentrations exists in the subsurface soils near the
former above ground solvent tank area at the Site. The full
extent of both ground water and soil contamination will be
determined during pre-design investigations as part of remedial
design.
EPA acknowledges that there are uncertainties regarding the
local hydrogeology at the Site, particularly with respect to the
possible presence of underlying fractures, sinkholes, and
solution channels in the vicinity of the Site. These aquifer
characteristics will be further determined during pre-design
investigations. However, EPA believes there is sufficient
information available at this time to select the remedy for
addressing the contamination present at the Site. The Selected
Remedy is set forth in the Record Of Decision.
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The analytical results generated during the RI were based on
data of known quality. These data were thoroughly reviewed and
evaluated to determine or quantify any uncertainties in the
analytical results. The levels of data quality were selected
during the RI/FS scoping process in order to meet the intended
use of the data (e.g. risk assessment purposes). All data were
validated in accordance with EPA guidelines, depending on
analytical parameters. EPA does not believe that the use of
these data biases the risk assessment performed for the Site.
As a conservative approach and consistent with EPA guidance,
the risk assessment assumed that future land use at the Site
could involve a residential scenario for both adult and child
residents. False positive chemical detections and analytical
results for contaminated blanks were not used in the risk
assessment. See also EPA response presented in Part II, Section
A, Comment (la).
The FS report evaluated potential remedial alternatives to
address contaminated media of concern at the Site using standard
engineering practice and EPA's previous experience with site
remediation. Sufficient information is available regarding the
nature and extent of contamination at the Site to select the
remedy for addressing the contamination present at the site.
Based on the RI results, the FS assumed that VOCs and metals
were the ground water contaminants of concern associated with the
Site. At this time, EPA does not believe that semi-volatile
organic compounds or DNAPLs are of concern for the ground water
contamination present at the Site. Therefore the ground water
extraction and treatment system set forth in the ROD includes
components to primarily address VOCs and metals. If Site related
contaminants which the Selected Remedy fails to remediate are
identified in the future, the ROD specifically addresses such a
determination. See EPA response presented in Part II, Section B,
Comment (f) .
i. On page 15 of the Proposed Plan, which sets forth EPA's
preferred alternative, EPA proposes to demolish the
structure located on the AIW Frank property. We believe it
would be more beneficial to both the environment and the
productive use of the propoerty to simply leave the
structure, rather than demolish it, so that it can be
renovated and put back to good use in the future.
Furthermore, we do not believe CERCLA authorizes demolition
of the structure, given that there is no evidence of a
release of a hazardous substnace from the structure into the
environment.
EPA Response: The AIW Frank Corporation rear building, which is
a one story concrete/corrugated structure measuring 180 feet by
160 feet, has been specifically cited as an unsafe structure by
17
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the Finest White land Township building code officer. EPA agrees
that the building could possibly be restored to productive use in
the future, therefore, the Selected Remedy set forth in the
Record of Decision calls for the rear building, and any other on
site structure which poses a safety risk to on site workers when
carrying out the remedy or interferes with implementation of the
selected remedy called for in this ROD, to be demolished or
restored to code in accordance with all appropriate federal,
state and local regulations. Demolition of the rear building
would be appropriate and authorized under CERCLA in order to
ensure proper clean up of hazardous substances.
C. Consents of Valley Forge Chapter of Trout Unlimited
In three 2-page letters dated July 13, 14 & 15, 1995 respectively
and a one page letter dated August 10, 1995, representatives of
the Valley Forge Chapter of Trout Unlimited (VFCTU) commented on
the Proposed Plan for the Site. The letters raised concerns
regarding the discharge of the treated groundwater* to West Valley
Creek, in particular that the potential for thermal degradation
of West Valley Creek as a result of the actions described in the
Proposed Plan has not been adequately addressed. The VFCTU
letter suggested that other discharge alternatives be considered
to prevent any further thermal degradation to West Valley Creek.
Specifically suggested discharge alternatives were: spray
irrigation, injection back into the aquifer, sale of the water to
Philadelphia Suburban Water Company, and discharge to PennDOT
wetland mitigation.
EPA Response; EPA understands and shares the concern that the
members of Trout Unlimited have regarding the protection of the
water quality, and recreational uses of West Valley Creek. As a
cold water fishery downstream of the Site, West Valley Creek has
strict temperature and dissolved oxygen content requirements
which the discharge must meet. Effluent and downstream
temperature sampling will be required pridr to and during the
operation of the system in order to ensure that the thermal
conditions of the stream are not altered. If sampling data
indicates that conditions in the stream may bef altered by the
treatment system, actions will be taken to assure that the
treated effluent discharge will comply with the NPDES
requirements listed as ARARs to the ROD.
Based on comments received during the public comment period,
EPA has considered alternative discharge options for the
treatment system discharge including: 1) discharge to West Valley
Creek as described in the proposed plan; 2) discharge to the on
Site pond; and 3) spray irrigation of the treated water in the
proposed West Whiteland Township spray irrigation POTW system.
The final discharge method could be any one or a combination of
the three options described above. A complete discussion of
these discharge options can be found in Section XI.A. of the ROD.
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Discharge to West Valley Creek has been retained as an option,
because of the thermal mitigation benefits (i.e. discharging cool
treated water directly to the Creek) it would provide in the
event that the extraction and treatment system does impact the
thermal regime of West Valley Creek. Also, see EPA responses
presented in Part I, Section A, Responses #2, #3, #4, #5 & #7 for
further information and details.
D. Comments of West Chester Fish, Game & wildlife Association
In a 3-page letter dated July 13, 1995 the West Chester Fish,
Game & Wildlife Association (W.C.F.6. & W.) commented on the
Proposed Plan for the Site. The W.C.F.G & W. letter raised
several concerns regarding the potential impacts of the discharge
of treated groundwater described in the Proposed Plan. The
concerns are as follows:
1. The removal of 432,000 gallons per day from the
groundwater aquifer and sending it downstream, has to
adversely effect the aquifer, because of the lack of
recharge.
2. An additional flow into West Valley Creek of 432,000
gallons per day at the clean up site, will cause bank
erosion and thus increase sedimentation.-
3. We oppose sending the treated groundwater to a public
sewer system.
4. We recommend the use of spray irrigation or deep well
injection in another area to get maximum groundwater
recharge.
EPA Response; EPA recognizes the concerns that the members of
W.C.F.G & W. have regarding the protection of the water quality,
and recreational uses of West Valley Creek and the aquifer in the
Site vicinity. Based on comments received during the public
comment period, EPA conducted a more detailed design-like
reevaluation of the volume of water to be treated. As a result,
it is currently estimated that the system will routinely treat
and discharge approximately 140 gpm. This translates into
slightly more than 200,000 gallons per day. West Valley Creek
currently has a flow rate of .465 cubic feet per second ("cfs")
at the discharge point contemplated in the Proposed Plan, during
typical low flow conditions (mid to late summer). The 140 gpm
discharge translates into an additional flow of .307 cfs, which
would account for 39% of the total stream flow during low flow
conditions. The depth of water in the Creek at the discharge
location would likely increase by 3/4 to 1 inch, again during low
flow conditions. During normal and high flow conditions the
percent increase in flow due to treated effluent discharge would
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significantly decrease. Therefore bank erosion and increased
sedimentation would not occur as a result of the treated water
effluent. Typically, bank erosion and sedimentation occurs
during very high flow events.
Based on comments received during the public comment period,
EPA has considered alternative discharge options for the
treatment system discharge including: 1) discharge to West Valley
Creek as described in the proposed plan; 2) discharge to the on
Site pond; and 3) spray irrigation of the treated water in the
proposed West Whiteland Township spray irrigation POTW system.
The final discharge method could be any one or a combination of
the three options described above. A complete discussion of
these discharge options is in Section XI.A. of the ROD.
Also, see EPA responses presented above in Part I, Section A,
Responses #2, #4, & #7 for further information and details.
The W.C.F.G & w. letter also suggests that EPA consider the
following discharge alternative:
We urge EPA to work with Philadelphia Suburban Water Company
and West Whiteland Township to use treated water from the
cleanup project. A current Philadelphia Suburban well could
be shut down to conserve groundwater and your treated, safe,
drinkable water could be sold to the water company for
additional processing and then resold to the general public.
It would ultimately be returned to the aquifer by land
application.
EPA Response: Sale of the treated effluent to Philadelphia
Suburban Water Company ("PSWC") was not specifically evaluated by
EPA in the Feasibility Study Report. However, based on comments
received during the public comment period, EPA contacted and
provided detailed information regarding the extraction and
treatment system proposed to representatives of PSWC, to
determine their potential interest in such an arrangement. In a
letter dated August 17, 1995 PSWC responded to EPA's inquiry. In
summary the letter states, "... PSWC could not at this time
seriously entertain a proposal to use the discharge from the
ground water remediation as a potable water source. The
disparate goals of ensuring a high quality public water supply
and achieving site clean up under strict EPA requirements present
serious complications and obstacles (technical, legal and
political) to such a proposal." Therefore, EPA has determined
that sale of the treated water discharge is not an implementable
option. A complete copy of the August 17, 1995 PSWC letter is in
the Administrative Record.
E. Comments of West Whiteland Township officials
In a two page letter dated July 10, 1995, the West Whiteland
Township Board of Supervisors raised concerns regarding the
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disposition of the treated water. The letter states that stream
discharge of all the water appears to be extremely wasteful and
unacceptable when other more desirable options exist such as:
1. Return of some portion of the water to the wetlands as
needed to maintain them.
2. Return of some portion of the water to the 12 mile pond
(the pond is located on Church Farm School property)
especially in summer to maintain its viability.
3. Spray irrigation to recharge groundwater.
4. Return of some portion of the water as discharge to
Valley Creek to maintain low enough temperature (cool) and
flow for trout viability and health.
*
5. Return some water directly to groundwater via wells or
injection.
6. If high enough quality, consider selling water to
Philadelphia Suburban Water Company.
The letter suggests that a combination of some or all of the
above options is preferable to total stream discharge.
EPA Response; EPA understands the concerns Township officials
have regarding the treated effluent discharge. Based on comments
received during the public comment period, EPA has considered
alternative discharge options for the treatment system discharge
including: 1) discharge to West Valley Creek as described in the
proposed plan; 2) discharge to the on Site pond; and 3) spray
irrigation of the treated water in the proposed West Whiteland
Township spray irrigation POTW system. The final discharge
method could be any one or a combination of the three options
described above. A complete discussion of these discharge
options can be found in Section XI.A. of the ROD.
Discharge to West Valley Creek has been retained as an
option, because of the thermal mitigation benefits (i.e.
discharging cool treated water directly to the Creek) it would
provide in the event that the extraction and treatment system
does impact the thermal regime of West Valley Creek.
Spray irrigation could potentially provide an alternative to
direct stream discharge and provide for aguifer recharge.
However, EPA has learned that most spray irrigation systems in
operation do require a limited stream discharge under certain
conditions to control costs. The proposed West Whiteland spray
irrigation POTW is in the conceptual design phase, therefore, at
this time, EPA does not have enough detailed information to
21
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accurately weigh this discharge option against the other
discharge alternatives. However, EPA has selected spray
irrigation through the West Whiteland POTW system as one of the
discharge points it may utilize as part of the Selected Remedy.
If after more detailed information is available it is determined
during the remedial design that spray irrigation provides the
best balance of tradeoffs when weighed against the other -two
discharge point options it will be incorporated into the design
and implemented.
The potential benefits to discharging to the PENNDCT
wetlands area would include avoidance of direct discharge to West
Valley Creek and partial recharge of the aquifer. However,
discharge to the on site pond provides the same benefits
regarding avoidance of direct discharge to West Valley Creek and
partial recharge of the aquifer though the pond area and through
the intermittent portion of West Valley Creek just vest of the
pond and east of Ship Road, while minimizing the impacts on the
wetlands areas on and off site. Discharge to the on site pond
would reduce the eventual total amount of discharge directly to
West Valley Creek through evaporation, as well as through ground
water recharge. See EPA responses presented in Part I", Section
A, Responses fl, #2, f3, #4, #5 & #7 for further information and
details.
In a one page letter dated July 14, 1995, the West Whiteland
Township Planning Commission raised concerns regarding the
discharge of treated groundwater to West Valley Creek as
described in the Proposed Plan. The letter suggests the
following discharge alternatives:
1. Spray Irrigation;
2. Injection back into the aquifer (wells);
3. Pond, or wetland disposal (two new ponds and two
new areas of wetland are in the area).
EPA Response; EPA shares these concerns. Please see EPA response
presented immediately above. Also, see EPA responses presented
in Part I, Section A, Responses #2, #3, & #4.
Attached to both the Planning Commission letter and -the Board of
Supervisors letter were the following "Question/Comments for the
Environmental Protection Agency (EPA) regarding the A.I.W.F.
Remediation":
1. West Whiteland Township is definitely concerned vith he
impact of drawing three hundred gallons per minute on the
carbonate geological structure in that area, please
investigate this issue and advise us on the impact of -this
drawdown on the carbonate structure. Being sensitive to the
issue of sinkholes and carbonate rock formation, West
Whiteland Township was a leader in developing ordinance
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protection since the early 1980's. This general area
already contains many sinkholes.
EPA Response; EPA recognizes and appreciates that sinkholes are
a legitimate concern in the Site vicinity. Please see EPA
response presented in Part I, Section A, Response #6 above
regarding sinkholes.
2. West Whiteland township will be facing problems in the
near future with sewage capacity at the Downingtown Area
Regional Authority ("DARA")treatment facility. You should
be advised that the Township is not in favor, at this time,
of sending the treated effluent from the AIWF site through
our public sewer system to DARA.
EPA Response; Discharge to the DARA POTW was considered and
carried through the detailed analysis portion of the Feasibility
Study Report for the Site. However, due to implementability and
cost concerns raised prior to the issuance of the Proposed Plan,
discharge to the DARA POTtf was not a component of the preferred
alternative presented in the Proposed Plan and is not a component
of the Selected Remedy presented in the Record of Decision. It
should be noted that the Selected Remedy does include the
possibility of discharging to the proposed West Whiteland spray
irrigation POTff.
3. You advised us that there would be a twenty-five to
thirty year time frame for this remedial project to be
completed. Could you provide us with an estimated time
frame with special emphasis on the first few years
indicating when the design will begin, when it will end,
when construction will begin, when waterline placement and
house connections will be done, etc., etc.
EPA Response; EPA understands and shares the Townships' and
local citizens concerns regarding prompt implementation of the
Selected Remedy. However, at this time it is difficult to
predict when remedial design and remedial action will occur.
Following the issuance of the Record of Decision, EPA will begin
formal negotiations with Potentially Responsible Parties ("PRPs")
which EPA has concluded are responsible for contain! nation found
at the Site. The negotiations will be conducted in an attempt to
have the PRPs consensually implement the Selected Remedy
described in the Record of Decision. Typically the negotiation
process takes approximately 3 to 6 months. Also, at this time it
is impossible to predict if the EPA budget for 1996 will. provide
EPA the ability to fund the implementation of the Selected Remedy
should PRPs not do the work.
For some portions of the Selected Remedy (i.e. the ground
water extraction and treatment system) the Remedial Design could
take over a year to develop. Other portions of the Selected
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Remedy may be able to be designed and implemented more quickly.
Following remedial design, the installation of the waterline
should take approximately 6 months. Similarly, the drum and sump
removal, building demolition/restoration, as well as the soil
excavation remedial actions should take approximately 6 months to
one year to implement after the remedial design is complete.
A schedule for cleanup activities will be developed during
the Remedial Design. EPA will keep citizens informed of the time
table for implementation of the selected remedy through
distribution of fact sheets and periodic public meetings.
4. We are very concerned with the impact of the quantity of
discharge to Valley Creek on the existing stream and at the
pond in the middle of Meadowbrook Manor. Kindly provide
information as to the percent increase in stream volume of
this three hundred gallons per minute as well as what impact
it will have on the existing pond. Also, provide
information on how the remediation process will stop during
heavy flooding so as not to cause additional flooding to
those residents in Meadowbrook Manor.
EPA Response; EPA understands the concerns Township officials
have regarding the treated effluent discharge and any potential
impact it may have on the Meadowbrook Manor pond. Based on
comments received during the public comment period, EPA has
considered alternative discharge options for.the treatment system
discharge including: 1) discharge to West Valley Creek as
described in the proposed plan; 2) discharge to the on Site pond;
and 3) spray irrigation of the treated water in the proposed West
Whiteland Township spray irrigation POTW system. The final
discharge method could be any one or a combination of the three
options described above. EPA may not discharge directly to West
Valley Creek. However, in the event that this option is
implemented, it should be noted that the exact amount of water
that will be discharged will be determined during the Remedial
Design. The Proposed Plan estimated that the system would treat
a maximum of 300 gallons per minute ("gpm") . Based on comments
received during the public comment period, EPA conducted a more
detailed design-like reevaluation of the volume of water to be
treated. As a result, it is currently estimated that the system
will routinely treat and discharge approximately 140 gpm. This
translates into slightly more than 200,000 gallons per day. West
Valley Creek currently has a flow rate of .465 cubic feet per
second ("cfs") at the discharge point contemplated in the
Proposed Plan, during typical low flow conditions (mid to late
summer) . The 140 gpm discharge translates into an additional
flow of .307 cfs, which would account for 35% of the total stream
flow during low flow conditions. The depth of water in the Creek
at the discharge location would likely increase by 3/4 to 1 inch,
again during low flow conditions. During normal and high flow
conditions the percent increase in flow due to treated effluent
24
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discharge would significantly decrease. The depth of water in
the Creek at the discharge location would liJfeely increase by 3/4
to 1 inch, again during low flow conditions. During normal and
high flow conditions (flooding) the percent increase in flow due
to treated effluent discharge would significantly decrease. The
Selected Remedy must avoid, minimize and mitigate impacts on
floodplains, so to the extent the Meadowbrook Manor pond is
determined to be in a floodplain the Selected Remedy performance
standards will be met (see ROD Section IX.B.I.;.
5. West Whiteland is just beginning investigation into
treating sanitary sewage on the portion of Church Farm
School north of the Chester Valley Rail Line and south of
Swedesford Road via spray irrigation. In lieu of a Valley
Creek discharge on the west side of Ship Road, would EPA
consider spraying at least a portion of this treated
effluent in that area or even the area north of Swedesford
Road? Could EPA consider joining with West Whiteland
Township to add spray irrigation 430,000 gpd to the spray
irrigation study which is presently being performed by
Tatman & Lee as an option?
EPA Response; Based on comments received during the public
comment period, EPA has considered alternative methods for the
treatment system discharge including spray irrigation. Spray
.irrigation could potentially provide an alternative to direct
stream discharge and provide for aquifer recharge. However, EPA
has learned that most spray irrigation systems in operation do
require a limited stream discharge under certain conditions to
control costs. The proposed West Whiteland spray irrigation POTW
is in the conceptual design phase, therefore, at this time, EPA
does not have enough detailed information to accurately weigh
this discharge option against the other discharge alternatives.
However, EPA has selected spray irrigation through the West
Whiteland POTW system as one of the discharge points it may
utilize as part of the Selected Remedy. If after more detailed
information is available it is determined during the remedial
design that spray irrigation provides the best balance of
tradeoffs when weighed against the other two discharge point
options it will be incorporated into the design and implemented.
6. Have you considered possibly dredging a portion of
Meadowbrook Manor Pond so that it will hold more water and
provide freeboard for this additional water (i.e. act as a
detention basin) which you are proposing to discharge into
Valley Creek upstream of Meadowbrook Manor.
EPA Response; Dredging the Meadowbrook Manor pond was not
specifically evaluated by EPA. Based on comments received during
the proposed plan public comment period EPA considered the
dredging of the Meadowbrook Manor pond and has determined that it
will not be part of the Selected Remedy. However, the Selected
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Remedy must avoid, minimize and mitigate impacts on floodplains
so to the extent the Meadowbrook Manor pond is determined to be
in a floodplain, which is impacted by the Selected Remedy, it
will be addressed (see ROD Section IX.B.l.) .
7. PennOOT has constructed wetlands immediately downstream
in the vicinity of AIWF property on the east side of Ship
Road. These wetlands are not yet established and are
currently dry. They are presently constructing additional
wetlands on the west side of Ship Road. What is the
possibility of either discharging or spraying some of this
effluent into these wetland areas to serve the purpose of
primarily a detention type facility as wells any other
positive aspects which the wetlands might provide in this
discharge?
EPA Response; Based on comments received during the proposed
plan public comment period EPA evaluated this possibility.
Please see EPA response presented in Part I, Section A, Response
#3.
8. What is the actual quality of water which will be
discharged as it relates to drinking water. In other words,
is this treated effluent drinkable? Further, are fish
edible which would consume and live in this water?
EPA Response; EPA understands and shares the concern that local
citizens have regarding the protection of the water quality of
West Valley Creek. As a cold water fishery downstream of the
Site, West Valley Creek has strict water quality, temperature and
dissolved oxygen content requirements which the discharge must
meet. The requirements are part of the NPDES requirements, which
are established by the Pennsylvania Department of Environmental
Protection and are required to be met as ARARs for the Selected
Remedy. The NPDES discharge requirements include limits on total
suspended solids, total dissolved solids, pH, metals and organic
contaminants. Many of the limits meet or exceed drinking water
standards. However, others do not, such as the total dissolved
solids and total suspended solids limits. Further, this Selected
Remedy does not address the bacteriological contamination which
would be required to be addressed by a supplier of public
drinking water. While these limits will be protective of the
aquatic life in the stream they would not be acceptable for a
potable water supply. It is expected that the air stripping
treatment system will accomplish at least 99* removal of all site
related contaminants, and that the resulting treated effluent
will comply with the NPDES requirements.
Based on surface water and sediment sampling conducted as
part of the remedial investigation downstream of the site, there
is no reason to believe that fish in West Valley Creek have been
contaminated by Site related hazardous substances.
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9. During the initial construction of the wells, the
building demolition, etc., please advise as to the manner in
which the site will be accessed and egressed from the public
road system.
EPA Response; It is expected that the Site will be accessed from
Business Route-30 during Remedial Design and Remedial Action
("RD/RA") activities. However, not all RD/RA activities will be
conducted on site such as monitoring and extraction well
installation, sampling, pump tests, water line construction, etc.
Access for these activities will be arranged based on the
location of the activity and access agreements with any property
owners involved. EPA recognizes the potential for traffic delays
on Business Route 30 in the Site area and will attempt to
minimize any Site related traffic disturbance.
*
10. With regard to the construction of the wells, the
waterlines, the remedial building and stripping tower, as
well as the actual operation of the pumps and stripping
facility,.what impact will this have on neighbors with
regard to noise, dust, odor, and other similar negative
impacts?
EPA Response; Remedial Design/Remedial Action ("RD/RA*)
activities involving the use of heavy equipment and drilling rigs
will in the short term create elevated activity and location
specific noise. Well drilling is typically completed in a matter
of days. However, the excavation, grading and building
demolition activities may take several months to complete once
remedial action has begun. The long term operation of the air
stripper tower and its associated blower and pumps should not
create noise levels outside of the treatment building, or off
site. The long term operation of the air stripper treatment
system should not create odors. Dust control measures will be
taken during the building demolition, soil excavation and other
construction activities called for in the selected remedy. All
off site areas impacted by the construction activities during
remedy design, implementation and operation and maintenance shall
be graded, restored and revegetated.
11. What will be done to protect pedestrian interest and
providing their safety from the site?
EPA Response; While permanent fencing is not part of the
Selected Remedy for the Site set forth in the ROD, EPA expects
that during remedy implementation temporary fencing will be
erected by contractors performing the work to prevent pedestrian
access to the on site equipment and work areas.
12. We are concerned about other safety impacts to the
"neighbors'1 of this facility especially with regard to
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inhaling fumes from the stripping tower and drinking water
in the interim before they are tied into the public water
system, etc. Please advise as to how EPA will address these
concerns.
EPA Response; Contaminants in the emitted air from the air
stripping system will be captured by a vapor phase carbon
adsorption unit. Air emissions from the air stripping tower must
be reduced to the minimum attainable level through the use of the
Best Available Technology (BAT), 25 PA Code $ 127.12(a) (5) .
Those regulations require that emissions be reduced to the
minimum levels possible. At these levels any residual risk posed
by emissions from the air stripping tower are far below the
acceptable risk level established by EPA of l.-o x 10^ (or 1 in
1,000,000). The vapor phase carbon adsorption units will be
monitored (twice per month) and replaced on a periodic basis
which will ensure that no contaminant breakthrough will occur.
The selected remedy described in the Record of Decision for
the Site includes the provision of point of use carbon filtration
units to those residents/businesses whose wells have shown levels
of contaminants of concern above maximum contaminant levels
("MCLs") until such time as those residents/businesses are
connected to the public water line.
13. What is the ultimate disposition of the site once
everything at the AIWF property and the Mid-County Mustang
property is complete? Will it be sold? By whom? Who will
be the beneficiary of the funds received in the acquisition?
EPA Response; EPA is not the current owner of the Site
properties. EPA has, however, placed a lien on a portion of the
Site which would have to be satisfied before ownership of the
property could be transferred.. The owners of record are free to
sell these properties at any time: EPA's investigations and
response actions are not intended to interfere with those
actions. Except for satisfying any liens, the property owners
will receive the proceeds of any sale. However, the site owners
may be considered Responsible Parties for the Site, and thus
liable for clean up costs.
14. You have indicated that there would be deed
restrictions on future owners of this property. Do these
deed restrictions go beyond the drilling of wells on the
site to the extent that it may not be able to -be used for a
nursery, agricultural uses, or any other uses which would
use the soil? Further, will there be impacts on the
structural stability of the soil as a result of the remedial
action taken? The Township should be aware of this in the
issuance of future permits for structures and uses at that
site.
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EPA Response; The Selected Remedy described in the Record of
Decision for the site when fully implemented is intended to allot/
reuse of the properties; indeed, removing on site contamination
through implementation of the Selected Remedy will allow for more
flexible use of Site properties. Except for avoiding activities
that will interfere with the remediation of the Site, current and
future owners are free to use the Site properties in a manner
consistent with current land use and zoning laws. The Selected
Remedy includes institutional controls which will identify the
Site as property underlain by contaminated ground water. The
restrictions will prohibit installation of wells and use of
ground water in the area of the contaminant plume. There should
be no impacts on the structural stability of the Site soils once
the Selected Remedy is completed.
15. It should be noted that West Whiteland Township is in
favor of the demolition of the building, water tower, and
any other structures on site including the removal of the
five existing, buried fuel oil tanks. Is there anything
which the Township can do to assure that these will be done?
EPA Response; EPA understands the concerns of the Township and
appreciates their willingness to assist the agency. The selected
remedy described in the Record of Decision for the Site includes
demolition or restoration to code of Site structures. The rear
building, and any other on site structure which poses a safety
risk to on site workers when carrying out the remedy or
interferes with implementation of the selected remedy called for
in this ROD, will be demolished or restored to code in accordance
with all appropriate federal, state and local regulations. The
fuel oil underground storage tanks are specifically excluded from
Super fund authority and will not be addressed in the Super fund
actions at the Site. However, the USTs will be referred to the
appropriate State and Federal programs and will be addressed
under those programs in coordination with the Super fund
activities at the Site.
16. What is the potential of injecting the treated effluent
back into the ground to eliminate the discharge all
together?
EPA Response; Please refer to the EPA response presented in Part
I, Section A, response #4.
17. Have you considered disposing of the treated effluent
in different ways depending on seasonal and weather changes
such as stream discharge along with wetlands used, along
with pond storage, as well as spray irrigation, and
injecting the treated effluent into the ground?
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EPA Response; EPA did not consider the discharge of treated
effluent in different ways depending on seasonal and weather
changes in the Feasibility Study Report. However, the
combination of several treated effluent discharge options based
on seasonal and weather changes would unacceptably increase the
total capital costs for discharge, as well as present significant
operational control difficulties. The Selected Remedy described
in the Record of Decision for the Site includes several discharge
points of the treated effluent. Based on comments received
during the public comment period, EPA has considered alternative
methods for the treatment system discharge including: 1)
discharge to West Valley Creek; 2) discharge to the on Site pond;
and 3) spray irrigation of the treated water in the proposed West
Whiteland Township sewer spray irrigation system. A complete
discussion of these discharge alternatives can be found in
Section XI.A. of the ROD. Also, see EPA responses presented in
Part I, Section A, responses #2, $3 and #4 above.
18. The Township and the County have purchased 200+ acres
of the Church Farm School property including the 12 mile
pond, for recreational purposes at a cost of twelve million
dollars. The pond is very shallow; therefore, the Township
and the county are concerned that draw down of the aquifer
will damage or cause the pond to dry. What insurances will
EPA give that this will not happen?
EPA Response: The 12 mile pond is located up gradient of the
contaminant plume and it is not anticipated that extraction wells
will be located near the pond, therefore, it is highly unlikely
that the treatment system will have an impact on water levels in
the pond. EPA can not give assurances that the pond will not dry
up, however, because the potential drying of the pond is a
natural occurrence as evidenced when the pond level lowered
significantly this summer due to drought conditions resulting in
a fish kill.
F. Comments of Brandyvine conservancy
In a 3-page letter dated July 17, 1995, H. William Sellers of the
Brandywine Conservancy commented on the Proposed Plan for the
Site. The letter raised concerns that the potential for existing
sinkhole collapse and creation of additional sinkholes, along
with depletion of the aquifer as a result of the extraction and
treatment actions described in the Proposed Plan has not been
adequately addressed. The letter also raises the concern that
during warm weather the airstripper will raise the temperature of
the treated groundwater to the extent that discharge of the water
to West Valley Creek will have an adverse effect on aquatic life
in the cold water fishery. The Brandywine Conservancy suggested
that EPA join with West Whiteland Township in the Township's
proposed sewer treatment spray irrigation system or discharge a
30
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portion of the treated water to the 12 mile pond on the former
Church Farm School property.
EPA Response; EPA appreciated and seriously considered the
comments submitted by the Brandywine Conservancy. Please refer
to EPA responses presented in Part I, Section A, responses f2,
#6, and #7 above for a discussion of these points.
6. Comments of Clean Water Action
In a one page letter dated July 18, 1995 Clean Water Action
raised concerns regarding the discharge of treated groundwater
discharge options described in the Proposed Plan. The specific
questions and concerns raised follow:
1. What is the rationale for disposing of treated water into
Valley Creek, or DARA's sewage treatment plant?
EPA Response: The treated effluent discharge options in the
proposed plan included discharge to West Valley Creek and to the
local POTff (DARA) . EPA believed the preferred alternative
including discharge to West Valley Creek provided the best
balance of trade-offs among the alternatives evaluated with
respect to the nine NCP criteria. EPA carefully considered state
and community acceptance of the preferred alternative prior to
reaching the final decision regarding the remedy and treated
effluent discharge. In summary, the Selected Remedy described in
the Record of Decision including the discharge options described
in Part I, Section A, response fl of this responsiveness summary
is believed to provide the best balance of trade-offs among the
alternatives evaluated with respect to the nine NCP criteria.
2. Does dumping 324,000 gpd into Valley Creek, a tributary of
the Brandywine River, add to the River's constant flooding
problems?
EPA Response; EPA does not believe that the Selected Remedy set
forth in the Record of Decision will add to the flooding problems
of the Brandywine River. Also, please refer to the EPA response
presented in Part I, Section A, responses fl for a detailed
discussion of this point.
3. Is holding the water in lagoons and slowly releasing it into
Valley Creek or even spraying it on the land an option?
EPA Response; Possibly. Based on comments received during the
public comment period, EPA has considered alternative methods for
the treatment system discharge including spray irrigation. Spray
irrigation could potentially provide an alternative to direct
stream discharge and provide for aquifer recharge. However, EPA
has learned that most spray irrigation systems in operation do
require a limited stream discharge under certain conditions to
31
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control costs. The proposed West Whiteland spray irrigation POTtf
is in the conceptual design phase, therefore, at this time, EPA
does not have enough detailed information to accurately weigh
this discharge option against the other discharge alternatives.
However, EPA has selected spray irrigation through the West
Whiteland POTtf system as one of the discharge points it may
utilize as part of the Selected Remedy. If after more detailed
information is available it is determined during the remedial
design that spray irrigation provides the best balance of
tradeoffs when weighed against the other two discharge point
options it will be incorporated into the design and implemented.
See EPA response presented in Part I, Section A, response #2.
The letter also suggests that some of the water could be directed
to the PennOOT wetlands mitigation project and urges EPA to work
closely with West Whiteland Township Supervisors in developing
the final plan.
EPA Response; Please refer to the EPA response presented in Part
I, Section A, response $3 regarding discharge to the PennDOT
wetlands. EPA intends to keep the West Whiteland Township
Supervisors informed of Site activities, as well as working with
them to the greatest extent possible during remedial design and
implementation.
H. Comments of West Chester Area Municipal Authority
In a one page letter dated August 14, 1995, The West Chester Area
Municipal Authority raised concerns regarding the discharge of
treated groundwater discharge options described in the Proposed
Plan. The letter requests that EPA reconsider deep well re
injection or spray irrigation as discharge alternatives.
EPA Response; EPA understands the concerns of the Authority and
has carefully considered the discharge alternative suggested.
Please see EPA responses presented in Part I, Section A,
responses #2, and #4 above for detailed responses.
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